Closed consultation

Consultation responses on the review of MGN 372

Updated 15 July 2022

In response to the consultation carried out between 20 January 2020 to 13 April 2020, MCA received responses from 10 stakeholders from harbour authorities, commercial shipping, recreation, fishing, navigation consultants, Government departments, General Lighthouse Authority and offshore renewable energy developers. Comments and MCA response were as follows:

MGN372 Offshore Renewable Energy Installations (OREIs): Guidance to Mariners Operating in the Vicinity of UK OREIs

From	Section	Consultee Comments	MCA Response
1	2.2 Navigational Aids [referring to Recommendation O-117] 2.2.2 [referring to flashing characteristics] 2.2.3 [referring to charateristics of IPS] 2.2.4 [referring to IALA Recommendation O-114] 2.5 Markings [referring to fixed red aviation lights] 3.5 Visibility and Marking of Wave and Tidal Energy Installations [IALA Recommendation O-131 & O117]	This document is withdrawn and superseded by IALA Recommendation O-139. Typically yellow with a 1s flash every 5s (Fl 5s) Typically yellow with a 5.5s flash every 2.5s (Fl 2.5s) This document is withdrawn and superseded by IALA Recommendation O-139. Aviation lights for offshore wind farms typically flash with a Morse W code in the UK. This document is withdrawn and superseded by IALA Recommendation O-139.	Amended to reference G1162 Added Added Amended to reference G1162 Added Amended to reference G1162
2	-	No specific comments on the tracked changes but it is [our] opinion that this guidance needs a complete overhaul to better align with current practices. In 2008, technology, shipping movements and a Mariners understanding of a wind farm development was much different to today’s reality and experience.	Document updated with more current information.
3	-	No comments. [We] will review how it might better promote this notice to other stakeholders particularly in the fishing industry .	Noted
4	4.3	4.3 refers to “the nominal safety zone around an operational wind turbine is expected to have a 50 metre radius”. To our knowledge there is only one windfarm (Barrow) operating a safety zones around operational wind turbines so pending confirming with BEIS this should be amended accordingly.	Safety zone information updated.
5	Track Changes	Comments and amendments in the MGN document using Track Changes	-
6	Track Changes	Comments and amendments in the MGN document using Track Changes	Comments noted and amended as appropriate
7	2.2.4 3.5 4 Annex 1	Updating of reference to IALA Recommendation O-139 Agreeing with corrections suggested by NLB referring to the updated IALA Recommendation O-139. Adding reference to DAERA, Northern Ireland in list of bodies requiring Safety Zone application. Updated to reflect sample marking from IALA Recommendation O-139	Amended to reference G1162 Amended to reference G1162 Added Amended to reference G1162
8	1.2 2.1	We note that the Guidance Note states that as of December 2018, 38 offshore windfarms where operational with a further eight in construction. We would ask that this information is updated to reflect the current status of the industry. Useful references include: • The Crown Estate Asset Map:https://www.thecrownestate.co.uk/en-gb/our-places/assetmap/ • Crown Estate Scotland Marine Assets:https://www.crownestatescotland.com/what-wedo/marine/asset/offshore-wind We note that whilst turbine height appears to have been updated in the Visibility and Appearance section, the visibility calculations have not. We would therefore ask that this is amended in the final version of the MGNs.	Updated links added to front page Updated
9	Track Changes	Comments and amendments in the MGN document using Track Changes	Comments noted and amended as appropriate
10	General 1.2 2 2.8 2.8.3 3 4 2.75 2.75 2.75 2 4.7.2 4.7.4 1.2 2.1 2.6 2.7.5 2.8.4 2.9.2 3.1 3.1.1 Annex Annex -	The relevence of this MGN being updated is to highlight to mariners who operate in the vicinty of a windfarm and hence with more developments being consented within sea areas then safety of navaigation around such sites will become more of an issue. Also redoing this m notice will refresh and highlight this especially to new officers and those who are studying for certificates of competency and may not have the basic knowledge that is assumed or required. The Mariners Handbook may not be studied as much as a new MGN both at college or onboard ships. Many mariners may not necessarily have operated within areas that have OWF that pose a risk to navigation. This MGN applies to fishermen hence should there be a section on fishing in the vicinity of the OWF which would additionally mention cables and thus should then MGN 661 (M+F) Navigation - safe and responsible anchoring and fishing practices be mentioned to be read at the in conjuction with this notice. Number of developments to be updated as per 2022, could highlight what floating wind farm sites are going through consenting. It may make this section clearer and easier to understand if diagrams are within this section directly showing an example of the layout. Perhaps this section 2 could only including lighting, markings and sound signals etc This could include reference to floating wind. Then move to next section on charting etc. Section could be updated for more recent reports. This point on the “Careful adjustment of radar controls can suppress some of these spurious radar returns but mariners are warned that there is a consequent risk of losing targets with a small radar cross section, which may include buoys or small craft, particularly yachts or GRP constructed craft, therefore due care should be taken in making such adjustments.” [It] Highlights the dangers of reduction of gain or increase of seaclutter and potential effects. Offshore Wave and Tidal Energy Installations - Section should be updated relating to the modern technologies available and also perhaps there could be more indepth diagrams showing these types of installation could be marked or indeed the structures could be moored subsea etc. Could this section explain and define safety zones, restricted zones and exclusion zones explaining the differences between these definitions giving clear advice to marininers. Marine coordination could be mentioned and its relationship with OWF’s and thus how non windfarm traffic is managed. Might be worth mentioning that higher traffic densities of windfarm employed vessels can be expected during construction periods or in summer months. Unmanned survey vessels are becoming more prevalent in offshore windfarms. These vessels tend to be small in size with a shallow profile. They operate within windfarm boundaries and along export cable routes. Typo in last sentence - “A good lookout should be therefore be maintained at all times” During construction of windfarms employing monopile turbines there is a period prior to the Transition Piece being installed that un painted monpiles sitting at or just above the surface. Not all turbines have ladder access. [ ] are trialling ladder free turbines that could become more prevalent in future. I believe helicopter rescues can only be conducted from the nacelle and not from the main access platform on the transition piece. The planned optional parks information is useful, do the MCA have any plans to attach areas of development in a map format at the end of the MGN? And update it say on annual basis? States “The turbines typically comprise: a foundation below sea level…”. Although previously mentioned it could be a floating structure I think would be useful to elaborate on this and basic configuration of a floating structure (could direct the MCA to the OWA study and most common floating systems, states confidential but worth asking Sol if drawing can be shared with MCA?). Comment as above, if submarine cables may be charted then floating surbine spreads should also be charted and mentioned to give greater clarity of beneath the waterline and seabed. Avoid anchoring except in emergencies when in close proximity to floating OREIs. To include mention of involved in the transfer of offshore technicians within “Small high speed vessels or larger vessels involved in turbine maintenance and safety duties may be encountered within or around a wind farm.” It could also be included within any amended text that offshore technicians travel to and from the turbines almost daily. States “In such conditions mariners are required, under Rule 5 Lookout to take into account information from other sources which may include sound signals and VHF information, for example from a VTS, or AIS. Mariners should bear in mind though that not all vessels are equipped with AIS. “ could then make reference to MGN 324 Navigation: Watchkeeping Safety - Use of VHFRadio and AIS (in relation to useage in collision avoidance). Typo of sheer to be amended to shear (wind shear). Missing full stop after “Wave energy convertors (WECs) capture kinetic energy carried by waves”. Missing full stop after “Movements along its length can be selectively constrained to produce energy”. Would be beneficial to include a basic drawing within MGN to show the maximum diameter of blades likely to be encountered when manoeuvring in close proximity to OWF and arrows showing rotational motion. Unlikely mariners are not aware of this but to emphasis the danger when at the planning stage of a passage plan. States recommended colour above waterline is yellow but the example shows red… Would it be possible to include an example with the colour yellow? Would be useful to include a small note in the appropriate section highlighting to mariners that during the different stages of a wind park there ie likely to be far more traffic in and outbound to site under construction, execution and decommissioning. Examples of types of vessels likely to be encountered (general overview?).	Noted and reference to MGN661 included Section updated It’s preferred to keep section 2 for wind and 3 and 4 for tide/wave and safety zones. New sub-paragraph added in section 2 for floating. New images will be added in the text. It was hoped to update the information through OWEC reseach however the project has been delayed. Noted. Reference added to additional research The examples still appear to be relevant however any suggestions for adding to the section would be gratefully received. Additional information added Added Added Amended Added to 2.2 Noted and added to 4.8.2 Paragraph amended to say helicopter rescue from the nacalle will not be possible and mariners will have to wait for evacuation by sea. No but a link to the 4COffshore map added for reference Additional paragraphs added to describe fixed and floating. If you have a good diagram we could use that would be appreciated. Otherwise we will find and reference another that is publically available. Additional note added to say the mooring spread will be charted on smaller scaled charts. Added Added Amended Amended Amended Section 2.1 updated to state direction of rotation and dimensions. New images will be added New images will be added