Niobe Exploration Well Environmental Statement

Transcription

Niobe Exploration Well
Environmental Statement
DECC Reference Number: W/4171/2014
November 2014
Version A
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
Address
28B Albyn Place
Aberdeen
AB10 1YL
Licensees/ Owners Working Interest
Trap Oil Ltd.
Norwegian Energy Company UK Limited
Short description
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:
 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/
Permits related to this project
Not Applicable
Significant environmental impacts
identified
None
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
8.2
8.3
Sources of Potential Impact .......................................................................... 8-1
8.4
8.5
Cumulative and Transboundary Impacts ....................................................... 8-4
8.6
8.7
8.8
Conclusions .................................................................................................. 8-5
9.0
ATMOSPHERIC EMISSIONS ....................................................................... 9-1
9.1
9.2
9.3
Sources of Potential Impact .......................................................................... 9-2
9.4
9.5
Cumulative and Transboundary Impacts ....................................................... 9-7
9.6
9.7
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
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
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
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
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
EU
European Union
EUNIS
European Nature Information Service
ft
feet
GEBCO
General Bathymetric Chart of the Oceans
GHG
Greenhouse Gas
2
Grams per square metre
2
g/ m / 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
g/ m
Km
2
Squared kilometres
LAT
Lowest Astronomical Tide
LTOBM
Low Toxicity Oil Based Mud
LWD
Logging While Drilling
µm
Micro metre(s)
m
Metre(s)
m
2
Squared metres
m
3
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
Block
A North Sea acreage sub-division measuring approximately 10km x 20km
forming part of a quadrant, e.g. Block 21/05 is the 5th block of Quadrant 21.
Blow-out preventer
System of valves connected to the wellhead while drilling, which can be
closed over the wellhead to prevent uncontrolled, sometimes explosive
release of hydrocarbons from the wellbore.
Centre for Environment,
Fisheries and Aquaculture
Science
The government agency which approves chemicals for offshore
use(amongst other functions).
Cephalopods
A class of mollusc characterised by bilateral body symmetry, reduction and
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.
Circalittoral
The area of the continental shelf sea-bed that lies below the zone of periodic
tidal exposure.
Copepods
Small crustaceans whose adult stage usually includes a single eye in the
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.
Demersal
The zone that is the part of the sea or ocean (or deep lake) comprising the
water column that is near to (and is significantly affected by) the seabed.
Dinoflagellates
A diverse group of eukaryotic algae that often have two protruding flagellae
used for propelling and directing the cell.
Dispersant
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
droplets, increasing the exposed surface area and increasing the rate of
degradation.
Drilling muds
A Mixture of chemicals pumped into a drilling rig chiefly as a lubricant for the
bit and shaft.
DTI
Historically the regulatory authority for the offshore oil and gas industry, this
agency has been dissolved and its energy-related responsibilities now fall to
DECC.
Dynamic Positioning
A system of sensors and thrusters on a vessel which allows it to maintain
position using satellite telemetry to adjust thrusters’ direction and power.
Ecological niche
A particular part of an ecological environment in which a particular plant or
animal species prospers.
Ecosystem
The physical environment and associated organisms that interact in a given
area. There is no defined size for an ecosystem.
Environmental Impact
Assessment
A process to identify and assess the impacts associated with a particular
activity, plan or project.
Environmental
Management System
A formal system which ensures that a company has control of its
environmental performance.
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Environmental sensitivity
the capacity of a habitat or organism to respond positively or negatively to
environmental change.
A report setting out the findings of an assessment of a project’s
environmental impacts.
Epifauna
Fauna inhabiting the surface of rocks, sediment or other fauna/flora.
European Commission
Body made up of commissioners from each EU country, responsible for
representing the common European interest, with the power to instigate and
apply changes in European law to all EU countries.
European protected
species
Species that are listed in Annex IV of the habitats directive, and are
therefore protected from harm or disturbance by European law.
Fauna
Animal life.
Flora
Plant life.
gas/oil gravity
Density expressed as a ratio of the weight of a specified volume of a
substance to the weight of an equal volume of another standard substance.
i.e. Fresh water / air
Hydrography
The measuring and mapping of depths, tides, and currents of a body of
water.
Infauna
Fauna that lives within sediments.
Log
The collection of data on the characteristics of a well.
Marine Scotland
A government consultee and a lead marine management organisation in
Scotland, bringing together the functions of the Scottish Fisheries Protection
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
Niche
An environment that is different from the surrounding area and that requires
the organisms exploiting it to be specialised in ways not generally found in
the surrounding area.
Notice to Mariners
Admiralty Notice to Mariners contain all the corrections, alterations and
amendments for the UK Hydrographic Office worldwide series of Admiralty
Charts and Publications, published weekly as booklets, which are
dispatched directly from the UKHO.
Organic
Compounds Containing Carbon and Hydrogen.
Pelagic
Any water in the sea that is not close to the bottom or near to the shore.
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.
Pill
Pills are slugs of chemical which are applied at the same density as the
mud, and are sent downhole to the location of the drilling problem.
Plankton
The collection of small or microscopic organisms, including algae and
protozoans, that float or drift in great numbers in fresh or salt water,
especially at or near the surface, and serve as food for fish and other larger
organisms.
Risk
The combination of the probability of an event and a measure of the
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.
Shale
A soft, clay-like sedimentary rock, made up of thin layers. Some shales of
lower-carboniferous age are oil bearing.
Stratification
Separation of a body of water into two or more distinct layers due to
differences in density or temperature.
Sublittoral
The area between the low water line and the edge of the continental shelf.
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Substrate
In this context, any surface which could provide a habitat for an organism to
live, i.e., a rock outcropping or area of sand.
Surge
A rise in water level above that expected due to tidal effects alone; the
primary causes are wind action and low atmospheric pressure.
Top-hole sections
The first drilling section.
Topography
The surface features of the seabed.
Transient
In this context, animals that tend to move through areas rather than stay in a
given area for a long period of time.
UK/Norway median line
The North Sea divide between UK and Norwegian waters.
UKCS
United Kingdom Continental shelf. Waters in which the UK Government has
jurisdiction over oil and gas activity.
Water column
A theoretical column through a body of water from the surface to the
sediments. This concept can be helpful when considering the different
processes that occur at different depths.
Zooplankton
Broadly defined as heterotrophic (deriving energy from organic matter)
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 recolonisation 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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Justification for Project
Project and
Environmental
Context
Options considered
• Justification for proposed
alternative
• Elimination of less appropriate
alternatives
Environmental Description
• Identification of sensitive components in the
physical, chemical, biological and socio-economic
environment
• Highlight critical data gaps
Project Description
• Identification of potential causes of
environmental impact and risk
• Highlight critical data gaps
Environmental Risk Assessment
• Application of defined assessment
criteria
• Justification for the assessment made
Risk Identification
and Assessment
Exclusion of insignificant impacts and
risks from further investigation in the EIA
Detailed
Assessment of
Significant
Impact and
Risks
Consultation throughout EIA with:
• Recognised environmental and technical
specialists
• Organisations with statutory responsibility
for the environment
• Individuals and organisations with a
legitimate interest in the environment of
the project
Focus investigation on significant
impacts and risks
Elimination from the project of
unacceptable impacts and risks
Detailed assessment of:
• Causes and consequences of environmental impacts
from planned activities
• Causes and potential consequences of oil spills and
other unplanned events
• Proposed environmental safeguards
• Response to concerns and issues raised by consultees
• 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
1
Co-ordinates
1
Latitude and Longitude
58° 06’ 42.821” N;
02° 41’ 43.398” W
Eastings and Northings
517 950 E;
6 441 355 N
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)
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
size (“)
Section
length (m)
Mud System
Weight of
cuttings (tonnes)
Cuttings disposal
route
36
76
Seawater/ GEL sweeps
135
Seabed
17½
625
WBM
262
Overboard
12¼
921
LTOBM
189
Skip and ship
366
LTOBM
36
Skip and ship
Contingency
*8½
* 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 121/4” 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 downhole 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
Survey and Habitat Assessment,
July 2014
Geophysical survey of the proposed well site
and potential relief well locations, comprising
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
GeoConsulting
Limited
Geotechnical survey, September
2014
Geotechnical survey of the jack-up location
comprising composite and PCPT Boreholes at
the spud can locations.
Anatec Ltd
Consent to locate and Collision
Risk Management plan, October
2014
Vessel traffic survey, collision frequency
assessment and review of effect on navigation.
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
contractor
Survey title
Description of survey data collected
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
Gardline
Mid-2011
Geophysical.
High resolution swath bathymetric survey.
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;
August 2011 (OWF cable route)
CMACS
12/10/2010 – 14/10/2011
Partrac
09/04/2010 – 10/04/2010
Benthic.
Benthic ecological information.
Sediment sampling.
Photographic and video information of seabed.
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;
summer)
Gargano
November 2010 to January 2011
(31 days; winter)
Shipping.
AIS and radar tracks by ship type.
Seasonal surveys.
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.
Project Description
Year
Block
DECC Reference
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 lowenergy 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)
observational results
Beatrice Alpha oil platform
(< 1 year) results
Cefas WaveNet buoy (3 years)
results
 Waves originating from a
northeast direction dominate.
 Wave heights are frequently
between 1 and 1.5 m.
 The maximum wave height is
6.29 m, originating from the
east-southeast.
 The frequent mean wave
period is between 7 and 8
seconds, indicative of swell
waves.
 During the summer, the
modal wave height was
1 m, and the maximum 3 m;
 During the winter, the
modal wave height was
1.5 m, and the maximum
8 m;
 Higher period waves,
approximately, 5 seconds
occur in the winter period.
 Waves originating from a
northeast direction dominate.
 The maximum wave height is
5.5 m, originating from the
east-northeast.
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
Significant Wave Height (Hs – m)
Return Period (years)
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.
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
A5 Sub littoral sediment
Habitat
Biotope Complex
A5.1 Circa littoral coarse
sediment
A5.14 Circa littoral coarse sediment
A5.15 Deep circa littoral coarse sediment
A5.25 Circa littoral fine sand
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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Figure 4.6: Biotope types around the Niobe Exploration Well
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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
to Niobe Well, km)
THC
PAH
Cr
Ni
Cu
Zn
Cd
Hg
Ba
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
40
20
40
-
0.4
0.3
-
Guideline Levels (where levels are provided)
CEFAS Action
Level
Canadian
1
-
-
2
-
-
400
200
400
-
0.5
3
-
ISQG
-
-
52.3
-
18.7
-
0.7
0.13
-
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
-1
Central North Sea (µgg dry weight) (Min- Max range)
Estuaries (CEFAS,
2001a)
-
0.2-28
-
-
-
-
-
-
-
Offshore (CEFAS,
2001a)
17-120
0.2-2.7
-
9.5
3.96
20.87
0.43
0.16
-
Oil and Gas
Installations (CEFAS,
2001a)
10-450
0.0274.7
-
17.79
17.45
129.74
0.85
0.36
-
Background
Concentration
(UKOOA, 2001)
9.41
(40.10)
0.068
(0.237)
9.1
(31)
11.46
(21.75)
6.32
(18.00)
21.28
(43.40)
0.76
(1.00)
0.76
(1.00)
348.47
(720.0
0)
-
-
60-81
30-36
20
90
0.2
0.05
-
Background
Concentration (OSPAR,
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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Dec
Nov
Oct
Sep
Aug
July
May
Apr
Mar
Feb
Jan
Species
June
Seasonality of Spawning (Peak spawning *)
Nursery
Table 4.9: Block spawning and nursery periods in the vicinity of, and including, the
√
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.)
Cod
(Gadus morhua)
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
Predominantly demersal fish but are pelagic during the first six months of larval
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)
Herring
(Clupea harengus)
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
Undergo metamorphosis after 2 to 7 months depending on spawning time¹
Once hatched, the herring larvae become pelagic and are distributed by the
1
prevailing currents
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), whitebeaked 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
Dec
Nov
Oct
Sept
Aug
July
June
Apr
Mar
Feb
Jan
Species
May
Seasonality of Density
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 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).
Block
Jan
Feb
Mar
Apr
May
June
July
Aug
Sep
Oct
Nov
Dec
All
Table 4.12: Seabird vulnerability in Block 12/27
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
Fulmar
Gannet
Great Skua
Kittiwake
Herring Gull
Great Black-Backed Gull
Artic Tern
Guillemot
Razorbill
Little Auk
Puffin
Count
Summer
Winter
Abundance
272
69
Density
2.18 km
Abundance
53
Density
0.42 km
Abundance
46
Density
0.37 km
Abundance
910
Density
7.30 km
Abundance
3
Density
0.03 km
Abundance
123
Density
0.99 km
Abundance
104
Density
0.83 km
Abundance
2,926
2
0.55 km
12
2
0.10 km
0
121
2
0.97 km
2
19
2
0.15 km
2
48
2
0.39 km
2
0
2
0
430
23.48 km
Abundance
842
2
3.45 km
2
452
2
Density
6.76 km
Abundance
0
69
Density
0
0.55 km
Abundance
839
6.74 km
2
0
2
Density
Density
2
3.63 km
2
2
197
2
1.58 km
2
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
in UK offshore waters
Species listed in Annex II known to occur in UK
offshore waters
 Sandbanks which are slightly covered by
seawater all the time.
 Grey seal.
 Reefs (bedrock, biogenic and stony).
 Bottlenose dolphin.



Bedrock reefs – made from continuous
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.
 Harbour or common seal.
 Harbour porpoise.
 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
Site Name
Main conservation interest (marine
components)
Moray Firth
 Subtidal sandbanks.
 Bottlenose dolphins.
Dornoch Firth and
Morrich More





Berriedale and
Langwell Waters
 Atlantic salmon.
River Spey
Area (ha)
Approx. distance
from well (km)
15,1347
50
8,700
79
58
48
 Sea lamprey.
 Freshwater pearl mussel.
5,729
55
River Evelix
20
90
River Oykel
960
110
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Reefs.
Subtidal sandbanks.
Estuaries.
Intertidal mudflats and sandflats.
Harbour seal.
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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
Gear
2011
2012
Effort
(Days)
% effort
Effort
(Days)
% effort
Effort
(Days)
% effort
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
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
680
100
453
100
490
100
Otter trawls - bottom
TOTALS
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
Species Type
2011
2012
Value (£)
Quantity
(tonnes)
Value (£)
Quantity
(tonnes)
Value (£)
Quantity
(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
2012
400
Quantity (tonnes)
350
300
250
200
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
No.
Description
CPA
(nm)
Bearing
(°)
Ships
per year
% of
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
326
100
TOTAL
*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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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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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
(km) and direction to/
from the well
Field name
Hydrocarbon
Type
Operator
Status
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
o
o
o
o
Commercial fishing – moderate activity.
Shipping – low shipping density.
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.
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).
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
Requires
consideration?
Closest
distance to
well (km)
Commercial
Fisheries

n/a
Moderate activity recorded,
though potential high
4.5.1
Shipping

n/a
Very low shipping density
4.5.2
4.5.3
Marine User Type
Section
Reference
Description
Oil and Gas Industry

15
Nine developments, of which
six are operational and one is
under development. In
addition, three pipelines are
within the Moray Firth.
Communications

25.4
SHEFA-2 Telecomms Cable
to the east, outwith block.
4.5.4

At same
location as well
Both surface and sub-surface
activities occur.
Two unexploded ordnances
have been noted to the east
4.5.5
Two consented wind farms,
earliest construction expected
2015.
4.5.7
One known wreck to the east
(MINSK Cargo Steamer)
4.5.8
Military Activities
Marine Renewables,
including Offshore
Wind

Wrecks and
Archaeological Sites

Waste Disposal Sites
X
Gas Storage and
Carbon Capture
Activities

Marine Aggregate
Extraction Activities
X
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Overlapping
with well
location
2.6
No marine waste disposal sites within the Moray
Firth
16
Saline aquifer site
4.5.6
No marine aggregate sites within the Moray Firth
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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:
 Only the proposed drilling operation no further field developments.
 Recommendations made in the DECC Guidance Notes.
 Nearby wind farm development stage and schedule in relation to the proposed period of drilling
operations.
 Details of a well test, if it is to be undertaken.
 Details on any vertical seismic profile (VSP) operations, if they are to be undertaken.
 Information on sensitive habitats and species at the drilling location.
 Information on seabed habitats at the drilling location from seabed survey results.
 A seabed habitat map detailing the proposed jack-up layout plan.
 Ministry of Defence Activity (MoD) details in relation to the drilling location.
 Broad coverage of Notice to Mariners.
 The most recent references where available.
Suncor can confirm the following:
 The ES is a single subject ES.
 The latest DECC EIA Guidance Notes have been used to prepare the ES.
 Nearby wind farm development stage(s) and schedule(s) are presented in Section 4.
 Suncor do not plan to undertake a well test as part of the Niobe Exploration Well.
 Should VSP be required Suncor will ensure the appropriate permit applications are
submitted (Section 3).
 Sensitive habitats and species information is presented in Section 4.
 Seabed habitats and survey information is presented in Section 4
 A seabed habitat map detailing the proposed jack-up layout plan is presented in
Section 4.
 MOD details are presented in Section 4.
 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:
 Marine mammals and associated impacts such as noise and corkscrew injuries are adequately
covered in the ES.
 Cumulative impacts covered in the ES should include the worst case scenario. Wind farms
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.
BMT Cordah Limited
Suncor can confirm the following:
 Marine mammals and associated impacts are presented in Sections 9 and 11.
 Cumulative impacts have been included with Sections 7 to 13.
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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
casual event will occur
X
A measure of the consequence
of the event occurring
=
The overall risk posed by
an activity
In terms of environmental impact assessment this can be defined as:
The likelihood
that a causal
event will occur
X
The likelihood that the
event will have an
impact upon a particular
environmental receptor
X
The magnitude/
severity of the effect
on the receptor
=
Significance of
the impact/
risk
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
upon a particular environmental receptor(s)
X
The magnitude
of the effect
=
Significance of
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.
Decreasing
likelihood
←
Table 6.1: Guidelines for assessing likelihood of occurrence of an impact upon a
particular receptor resulting from the planned activities
Likelihood
Frequency of planned activity impacting receptors during drilling
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
D
Unlikely
Impact rarely observed; has occurred only several times in industry
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/
consequence
Characteristics

5
Catastrophic


4
Severe


3
Major


2
Moderate


1
Minor

Adverse permanent impacts on key ecosystem functions in larger natural
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
activities.
Scale typically regional to national level.
Adverse medium term impacts on a significant part of habitats (e.g. restitution
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
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
level.
Scale typically transient and highly localised.
Table 6.3: Environmental risk assessment matrix
Likelihood of occurrence (Table 6.1 and 6.4)
Magnitude/ consequence of impact (Table 6.2)
Planned
Accidental
A
Definite
B
1
Minor
2
Moderate
3
Major
4
Severe
5
Catastrophic
Likely
Low
A1
Medium
A2
Medium
A3
High
A4
High
A5
Likely
Unlikely
Low
B1
Medium
B2
Medium
B3
High
B4
High
B5
C
Possible
Very unlikely
Low
C1
Low
C2
Medium
C3
Medium
C4
High
C5
D
Unlikely
Extremely
unlikely
Negligible
D1
Low
D2
Low
D3
Medium
D4
Medium
D5
E
Remote
Almost
unheard of
Negligible
E1
Negligible
E2
Low
E3
Low
E4
Medium
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
occur
X
The magnitude of the effect
=
Significance of the
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.
Decreasing
likelihood
Table 6.4: Guidelines for assessing likelihood of occurrence of an impact resulting
from unplanned/ accidental activities
Likelihood
Frequency of an unplanned or accidental event occurring and
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
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
Accidental/
unplanned
event
Planned
event
Accidental/
unplanned
event
Planned
event
Accidental/
unplanned
event
High
Planned
event
Medium
Accidental/
unplanned
event
Low
Planned
event
Negligible
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
Project Stage
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Other users
Military operations
Shipping
Commercial fishing
Integrity of
conservation sites
Sea mammals
Seabirds
Finfish and shellfish
Water column
(plankton)
Sediment biology
(benthos)
Air quality (local)
Use of disposal
facilities
Use of resources
Water quality
High risk
Medium risk
Low risk
Sediment structure /
chemistry
Key
Impact justification section
reference
Socioeconomic
Overall significance
Biological
Stakeholder concerns
Physical and chemical
*These impacts may represent a cumulative impact from the exploration well
Trans-boundary effects
Table 6.6: Risk assessment of the drilling activities
A2
7
B2
8
B2
9
A1
B
A1
B
Drilling: Planned events

Physical presence of the jack-up drilling rig and vessels
Installation and removal of the jack-up drilling rig




Gaseous emissions from the jack-up drilling rig and vessels







Aqueous discharges from the jack-up drilling rig





Ballast water discharge from the jack-up drilling rig





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

C1*
B
VOCs from mud usage and fuel transfer
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

C4
13
C3
13
B3
13
A1
B
Drilling: Accidental/ Unplanned events
Well blow out of oil and gas













Hydrocarbon spill or release, e.g. from vessel collision













Spills of chemicals and muds







Objects dropped into the sea
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Other users
Military operations
Shipping
Commercial fishing
Integrity of
conservation sites
Sea mammals
Seabirds
Finfish and shellfish
Water column
(plankton)
Sediment biology
(benthos)
Air quality (local)
Use of disposal
facilities
Use of resources
Water quality
High risk
Medium risk
Low risk
Sediment structure /
chemistry
Key
Impact justification
section reference
Socioeconomic
Overall significance
Biological
Stakeholder concerns
Physical and chemical
*These impacts may represent a cumulative impact from the exploration well
Trans-boundary effects
Table 6.7: Risk assessment of the decommissioning activities associated with the Niobe Exploration Well
A2
7
B2
9
Decommissioning: Planned events

Physical presence of the vessels

Gaseous emissions from the vessels




Physical interaction between vessels and seals, i.e. ‘corkscrew’ deaths


C2
11
Underwater noise from the vessels


C2
12
A1
B
A1
B
Discharge of sewage and macerated waste





Plug and abandonment of well






Mechanical cutting of casing
Presence of cuttings piles













A1*
B
A3
10
C3
13
A1
B
Decommissioning: Accidental/ Unplanned events
Hydrocarbon spill or release, e.g. from vessel collision

Objects dropped into the sea
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






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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
vessels with other users of the sea







7.8
Notification of drilling activities on the Kingfisher
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.
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.
8.2
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
Jack-up placement on the seabed (3 spud cans)
2
(0.015 km / 2) x 3.14 x 3
Total area of seabed disturbance from the jack-up drilling rig
2
Footprint area (km )
0.00053
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
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 resuspension 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.
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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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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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.
9.2
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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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
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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Table 9.1: Environmental effects of atmospheric emissions
Gaseous emission
100-year
GWP factor*
Environmental effect
Direct greenhouse gases
Carbon dioxide (CO2)
CO2 is a greenhouse gas, meaning that it inhibits the
radiation of heat into space, which may increase
temperatures at the Earth’s surface.
1
Methane (CH4)
May contribute to climate change.
23
Nitrous oxide (N2O)
May contribute to climate change.
296
Indirect greenhouse gases
Carbon monoxide (CO)
Direct effects upon human health (asphyxiate). May
contribute indirectly to climate change.
Oxides of nitrogen (NOx)
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
formation. It also contributes to acid deposition (wet and
dry) which can impact freshwater and terrestrial
ecosystems.
5**
Volatile organic
compounds (VOC)
Volatile organic compounds (VOCs), which include nonmethane 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
climate through their production of organic aerosols and
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.
n/a
Sulphur dioxide (SO2)
SO2 has direct health effects - causes respiratory illness. It
also contributes to acid deposition (wet and dry), which can
impact freshwater and terrestrial ecosystems.
n/a
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
typically in the size range of 100 nanometers (0.1
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.
n/a
3
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 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
production during 2010*
16,393,119
24,649
55,837
1,006
2,628
50,476
54,050
Total vessel emissions from
the drilling operations as a
percentage of 2010 UKCS
emissions from offshore oil
and gas activities
0.03
0.05
0.15
0.03
0.21
0.00
0.01
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
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
Activity
GWP emissions (tonnes)*
CO2
CO
NOx
N2O
SO2
CH4
VOC
Total GWP
Total GWP
emissions
from
drilling
operations
4,440.00
33.30
409.30
91.76
-
8.51
-
4,982.87
Total GWP
emissions
from
helicopter
flights
50.21
0.24
1.00
0.00
-
0.00
-
51.45
Total GWP
vessel
emissions
from the
drilling
operations
4,490.21
33.54
410.30
91.76
-
8.51
-
5,034.32
Emissions from UKCS Offshore Exploration and Production Activities
Total GWP
emissions
from
UKCS
offshore
exploration
and
production
during
2010
16,393,119
73,947
279,185
297,776
-
1,160,948
-
18,204,975
Total GWP
vessel
emissions
at the
drilling
operations
as a
percentag
e of 2010
UKCS
emissions
from
offshore oil
and gas
activities
0.03
0.05
0.15
0.03
-
0.00
-
0.03
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 CO 2 over the next 20 years.
Source: Oil and Gas UK (2012)
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9.5
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
atmospheric emissions arising from the Niobe Exploration Well are detailed in Table 9.4.
Consumption of fuel (diesel and aviation) by
the support vessels, jack-up drilling rig and
helicopters




9.8
Fuel consumption will be minimised by operational
practices and power management systems for
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.
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.
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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.
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
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
36”
17½”
12¼”
8½”
Total WBM
discharge to sea
(tonnes)
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
Block
Well
12/27
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
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
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.
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 drilling discharges are detailed in Table 10.2.
Drilling discharges to the marine
environment
 The drilling operation will be planned, managed and
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.
11.2
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
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
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.
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
miles of a harbour seal SAC and areas where the
1
harbour seal population is in significant decline .
 Consider alternatives to using ducted propellers
or,
 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
nautical miles of a harbour seal SAC and not
covered above.
 Consider alternatives to using ducted propellers.
 Avoid the breeding season if possible.
Activity proposed to take place within 4 nautical
miles of a grey seal SAC.
 Consider alternatives to using ducted propellers.
 Avoid the breeding season if possible.
Low
1
Activity proposed to take place beyond 30 nm
distance from a seal SAC.
 None.
Activity proposed to take place beyond 4nm
distance from a grey seal SAC.
 None.
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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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 whitebeaked 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
group
Estimated auditory bandwidth Species sighted in the Niobe Well
Exploration area
Low-frequency
7 Hz – 30 kHz
Minke whale
Fin whale
Long-finned pilot whale
Humpback whale
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
Single-pulse
Brief, broadband, atonal, transient, single discrete noise
events; characterised by rapid rise to peak pressure
There are no single pulse
events anticipated for the
Multiple-pulse
Multiple pulse events within 24 hours
There are no multiple pulse
events anticipated for the
Non-pulse
Intermittent or continuous, single or multiple discrete
acoustic events within 24 hours; tonal or atonal and
without rapid rise to peak pressure
Vessel activity, drilling
*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).
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 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.
Noise from drilling operations
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
 Machinery and equipment will be in good working order and wellmaintained.
 Suncor will undertake all drilling operations in 2015, prior to the
construction of the adjacent MORL development wind farm in
2016.
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.
Dispersion
Waves and turbulence at the sea surface can cause a slick to break up into
fragments and droplets of varying sizes which become mixed into the upper
levels of the water column.
Emulsification
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
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.
Dissolution
Some compounds in oil are water soluble and will dissolve into the
surrounding water.
Oxidation
Oils react chemically with oxygen either breaking down into soluble products
or forming persistent tars. This process is promoted by sunlight.
Sedimentation
Sinking is usually caused by the adhesion of sediment particles or organic
matter to the oil. In contrast to offshore, shallow waters are often laden with
suspended solids providing favourable conditions for sedimentation.
Biodegradation
Sea water contains a range of micro-organisms that can partially or
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
Oil type
Specific
gravity
API
(°)
Pour
point
Viscosity
(CP)
Wax
content
(%)
Asphaltene
content
(wt %)
Source
Niobe Crude Oil
0.94
24°
-32
50
1.6
0.16
C&C
Reservoir*
Analogue crude:
Skrugard 2011
0.871
31
-36
32
1.89
0.05
OSCAR
database
Marine Diesel
0.843
36.4
-36
-
-
-
OSCAR
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 blowout 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
Total
Quantity
Released
Release
Rate
Release
Duration
Crude oil
84,000 bbls
equivalent to
13,355 m³
700 bbls/day
equivalent to
111 m³/day
120 days
Diesel
2,000 bbls
2,000
bbls/day
1 hour
84,000 bbls
equivalent to
13,355 m³
700
bbls/day
equivalent
to 111
m³/day
120 days
D01b
Well blow-out spill with a 30
knots wind blowing towards the
UK/ Norwegian median line
84,000 bbls
equivalent to
13,355 m³
700
bbls/day
equivalent
to 111
m³/day
120 days
D02a
Loss of inventory from collision
of vessels with a 30 knots wind
blowing towards the UK
coastline
2,000 bbls
2,000
bbls/day
1 hour
D02b
Loss of inventory from a collision
of vessels with a 30 knots wind
blowing towards the UK/
Norwegian median line
2,000 bbls
2,000
bbls/day
1 hour
13.3.3
Stochastic modelling results
Scenario
Description
Oil Type
Stochastic modelling scenarios
S01
Well blow-out spill
S02
Loss of inventory from a collision
of vessels
Deterministic modelling scenarios
D01a
Well blow-out spill with a 30
knots wind blowing towards the
UK coastline
Crude oil
Diesel
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
Scenario
Description
Minimum arrival
time in a
simulation hours
Maximum volume
accumulating on shore
in a simulation (m³)*
Impact to
shore
S01
Well blow-out spill
19
2,840
Beaching in
mainland
Scotland and
Orkney Islands
S02
Loss of inventory from
a collision of vessels
13
1,443
Beaching in
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.
Description
Time until
surface oil
crosses
UK/Norway
median line
(d/h)
Time until
surface oil is
insignificant*
(d/h)
Minimum
arrival
time to
shore
(d/h)
Volume of
oil
beached
at the end
of the
simulation
(m³)**
Impact
to shore
D01a
Well blow-out spill with a
30 knots wind blowing
towards the UK
coastline
N/A
5d 6h
3d 21h
300
Beaching
in
Scotland
D01b
Well blow-out spill with a
30 knots wind blowing
towards the UK/
18d 6h
8d 9h
23d 6h
21
Beaching
in
Scotland
D02a
Loss of inventory from a
collision of vessels with
a 30 knots wind blowing
towards the UK
coastline
N/A
0d 12h
No
Beaching
No
Beaching
No
Beaching
D02b
Loss of inventory from a
collision of vessels with
a 30 knots wind blowing
towards the UK/
N/A
0d 15h
No
Beaching
No
Beaching
No
Beaching
Scenario
*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
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
receptor
Potential effect
Plankton
Localised effects due to toxicity.
Benthic fauna
Usually only localised effects from toxicity and smothering, and only if oil reached the
seabed. Benthic communities may be affected by gross contamination, with recovery
taking several years.
Fish
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
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.
Seabirds
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.
Birds are identified as being very vulnerable in the Niobe Exploration Well area
throughout the year.
Marine
mammals
No obvious effects are known for adult cetaceans or seals. Fouling of the fur of young
seals reduces their resistance to cold. Few direct impacts to marine mammals from a
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, longfinned 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
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.
Potential source of
impact
Planned Mitigation Measures
Spill of fuel, base oil,
diesel, lubricants, drilling
mud and chemicals
 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
monitor the hoses throughout bunkering.
 Visual inspection of hoses and offloading 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 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).
Loss of drilling rig
inventory (collision with
another vessel)
 The jack-up drilling rig fitted with all relevant navigational and
communication aids on board.
 Collision risk assessment and vessel management plans for field
operations.
 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.
Loss of well control
 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.
 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.
All spills
 Drilling operations at the Niobe Exploration Well will be covered by the
drilling specific OPEP.
 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
Section
7
8
Sources of
Potential Environmental Receptors
1.
Commercial fisheries.
2.
Commercial shipping.
3.
Offshore renewable energy:
 MORL wind farm.
 BOWL wind farm.
4.
MOD.
5.
Marine archaeology and wrecks
1.
Benthic environment:
 Sediments.
2.
Fish and shellfish:
 Nephrops.
3.
Protected habitats and species:
 East Caithness Cliffs MPA/ SAC/
SPA.
4.
Cumulative and transboundary:
 MORL wind farm development.
Other users of the sea
Installation of the drilling
rig on the seabed.
Suncor’s Planned Mitigation Measure





 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.
 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 scheduled construction of the adjacent
MORL wind farm development in 2016.

9
Atmospheric emissions
from the consumption of
fuel from:
 Jack-up drilling rig.
 Support vessels.
 Helicopters.
1.
Local air quality.
2.
Global climate change.
3.
 Norwegian waters.
Notification of the drilling activities on the Kingfisher fortnightly bulletin.
Notification of the drilling activities to the HM Coastguard and UK Hydrographic Office.
A 500 m safety exclusion zone will be in place around the drilling rig.
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).




The support vessels and drilling rig will be audited as part of selection and pre-mobilisation and
management system requirements.
Fuel consumption will be minimised by operational practices and power management systems for
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
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
Section
10
11
Sources of
1.
Water column communities:
 Plankton.
2.
Benthic communities:
 Benthic fauna.
3.
Fish and shellfish:
 Cod.
 Lemon sole.
 Nephrops.
 Sprat.
 Whiting.
4.
Protected habitats and species:
 East Caithness Cliffs MPA/ SAC/
SPA.
5.
1.
‘Corkscrew’ seal mortalities to:
 Grey seal.
 Harbour seal.
2.
Drilling discharges to the
marine environment.
Vessel interactions with
seals
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 The drilling operation will be planned, managed and monitored so as to minimise the volume of 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




Consider alternatives to using ducted propellers or,
Avoid the seal breeding season if possible (if avoiding the breeding season or using alternatives to
ducted propellers are not possible then a Seal Corkscrew Injury Monitoring Scheme will be considered)
Presence of a MMO on the drilling rig during VSP should VSP be required.
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Table 14.1 (continued): Summary of the potential impacts to the environment and Suncor’s planned mitigation measures
ES
Section
12
Sources of
1.
Fish.
2.
Pinnipeds.
 Grey seal.
 Harbour seal.
3.
Cetaceans:
 Bottlenose dolphin.
 Fin whale.
 Harbour porpoise.
 Humpback whale.
 Killer whale.
 Long-finned pilot whale.
 Minke whale.
 White-beaked dolphin.
Underwater noise from:
 Jack-up drilling rig.
 Support vessels.
 Helicopters.
4.
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



Machinery and equipment on the drilling rig and the support vessels will be in good working order and
will be well-maintained.
Helicopter maintenance will be undertaken by contractors in line with manufacturers and regulatory
requirements.
The number of vessels utilising DP will be minimised.
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Table 14.1 (continued): Summary of the potential impacts to the environment and Suncor’s planned mitigation measures
ES
Section
13
Sources of
1.
Plankton.
2.
Fish and shellfish:
 Cod.
 Lemon sole.
 Nephrops.
 Sprat.
 Whiting.
3.
Seabirds.
4.
Marine mammals.
5.
Accidental hydrocarbon
release
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 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
the hoses becoming twisted in the propellers.
 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 will be fitted with all relevant navigational and communication aids.
 A collision risk assessment and vessel management plans for field operations will be undertaken prior
to the commencement of operations.
 Simultaneous operation procedures will be in place governing concurrent operations in the Niobe well
area.
 A standby vessel will be onsite during the 45 day drilling period to monitor the exclusion zone around
the jack-up drilling rig.
 The contractor’s well procedures in place during well operations.
 Primary well control achieved through well engineering and the use of drilling mud formulations with
weighting agents.
 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
Accountability.

Element 10: Contractor Management.

Element 2: Risk Management.

Element 11: Data, Document and
Information Management.

Element 3: Legal Requirements and
Commitments.

Element 12: Emergency Management.

Element 4: Goals, Targets and Planning.

Element 13: Communications and
Stakeholder Relations.

Element 5: Management of Change.

Element 14: Quality Assurance.

Element 6: Structure, Responsibility and
Authority.

Element 15: Incident Management.

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
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Appendix A
Summary of Relevant Petroleum and Environmental Legislation
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A.1: General
Regulatory Body
Maritime and
Coastguard Agency
(MCA)
Legislation
Summary of Requirements
MARPOL 73/78
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:
 Annex I Regulations for the Prevention of Pollution by Oil (entered into force 2 October 1983)
 Annex II Regulations for the Control of Pollution by Noxious Liquid Substances in Bulk (entered into force 2 October 1983)
 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
MCA
DECC
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Legislation
MARPOL 73/78 Annex VI the Prevention of Air
Pollution from Ships
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.
Emissions arising directly from the exploration, exploitation and associated offshore processing of seabed mineral resources are exempt from Annex VI, including the following:
 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.
Petroleum Licensing (Production) (Seaward Areas)
Regulations 2008 (2008/225)
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
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,
flare consent will need to be obtained.
The Energy Act 1976
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
mostly used for issue of vent consents.
The National Emission Ceilings Regulations 2002
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 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
thereafter not to exceed the amounts specified in the Schedule of that pollutant.
The Merchant Shipping (Prevention of Air Pollution
from Ships) Regulations 2008 (as amended 2010)
These regulations implement Annex VI of MARPOL (the International Convention for the Prevention of Pollution from Ships 73/78) in the UK.
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.
Climate Change Act 2008
Climate Change (Scotland) Act 2009
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. 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,
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
DECC
Legislation
Offshore Combustion Installations (Prevention and
Control of Pollution) Regulations 2013.
The 2013 regulations transpose the relevant provisions of the Industrial Emissions Directive 2010/75/EU in respect to specific atmospheric pollutants from combustion installations
with a thermal capacity rating in excess of 50 MW on offshore platforms undertaking oil and gas production and gas and CO 2 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 Fluorinated Greenhouse Gases Regulations 2009
(as amended)
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
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
authorised persons to enforce these Regulations.
The Environmental Protection (Controls on Ozone
Depleting Substances) Regulations 2011
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,
export, placing on the market, recovery, recycling, reclamation and destruction of substances that deplete the ozone layer.
The Pollution Prevention and Control Act 1999 (as
amended)
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
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
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
Council Directive on the Assessment of the Effects of
Certain Public and Private Activities on the
Environment - 85/337/EEC (the EIA Directive) as
amended by Directives 97/11/EC, 2003/35/EC
and2009/31/EC.
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:
 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:
 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
the case of gas.
 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.
 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
effects of certain public and private projects on the
environment
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
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
developments are listed as Annex 1 projects.
OSPAR Recommendation 2010/5 on assessments of
environmental impact in relation to threatened and/or
declining species and habitats
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,
through assessments of environmental impacts of human activities. When assessments of environmental impacts of human activities that may affect the marine environment of the
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).
DECC
A.4: Access to Environmental Information and Public Participation
Regulatory Body
Legislation
Directive 2003/4/EC of the European Parliament and
of the Council of 28 January 2003 on public access to
environmental information and repealing Council
Directive 90/313/EEC
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
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
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
Information (Scotland) Regulations 2004.
DECC
The Environmental Information (Scotland) Regulations
2004
Public Participation Directive (PPD) 2003/35/EC
BMT Cordah Limited
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
The Offshore Marine Conservation (Natural Habitats,
&c.) Regulations 2007 as amended (2010)
The Offshore Petroleum Activities (Conservation of
Habitats) Regulations 2001 (as amended 2007)
The Conservation of Habitats and Species
Regulations 2010 (as amended 2012) and the
Conservation (Natural Habitats, &c.) Regulations 1994
(as amended)
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
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
Species (EPC) licences for certain activities and for undertaking monitoring and surveillance of offshore marine sites. The 2010 Amendment Regulations make various insertions for
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:
 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
Sites only as far as the limit of territorial waters (12nm from the coastline).
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.
 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
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
Marine (Scotland) Act 2010
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 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
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
Interest (SSSIs) and a statutory consultee for oil & gas ESs.
DECC, JNCC, SNH,
DEFRA
Wildlife and Countryside Act 1981 (Amendment)
(Scotland) Regulations 2001
BMT Cordah Limited
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A.6: Emergency response
Regulatory Body
Legislation
The Offshore Installations (Emergency Pollution
Control) Regulations 2002
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
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
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
implement effective control and preventative operations.
The Offshore Petroleum Activities (Oil Pollution
Prevention and Control) Regulations 2005 (as
amended 2011)
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
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
that it was undertaken as a matter of urgency for the purposes of securing the safety of any person.
OSPAR Recommendation 2010/18 on the prevention
of significant acute oil pollution from offshore drilling
activities
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:
 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
evaluate this on a case by case basis and prior to permitting;
 Take extra care to apply all relevant learning from the Deepwater Horizon accident;
 Report on this ongoing activity to OSPAR; and
 Based on the reviews undertaken, contracting parties should individually and jointly, if needed, take further action within the scope of the OSPAR Convention.
Merchant Shipping Act 1995
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
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,
Response and Co-operation) Regulations 1998 (as
amended 2001)
The Merchant Shipping (Oil Pollution Preparedness, Response and Co-operation Convention) Regulations 1998 introduce into UK law the oil spill planning requirements and legal
oil spill reporting requirements of the OPRC Convention.
DECC
DECC
A.7: Environmental Liability
Regulatory Body
DEFRA
SEPA, MS and SNH
Legislation
Directive 2004/35/CE of the European Parliament and
the Council of 21 April 2004 on environmental liability
with regard to the prevention and remedying of
environmental damage.
The Environmental Damage (Prevention and
Remediation) Regulations 2009
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.
The EC has published a communication (the Communication) on "facing the challenge of the safety of offshore oil and gas activities".
The European Commission is set to review the liability regime applicable to offshore petroleum activities and is:
 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
(as defined in the Marine Strategy Framework Directive 2008/56/EC).
 Re-considering introducing a mandatory requirement for operators to provide financial security in the event that a major accident occurs.
 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.
The Environmental Liability (Scotland) Regulations
2009 (as amended 2011)
These Regulations implement the EC Environmental Liability Directive in Scotland. The regulations oblige operators of certain activities to take preventative measures where there
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
DECC, Marine
Scotland, CEFAS
BMT Cordah Limited
Legislation
The Offshore Chemicals Regulations 2002 (as
amended)
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
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;
pipelines: PLA; production: PRA; decommissioning: DCA; and workovers and well interventions: WIA).
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
Environment of the North East Atlantic 1992 (OSPAR
Convention)
OSPAR Decision 2000/3 on the Use of Organic-Phase
Drilling Fluids (OPF) and the Discharge of OPFContaminated Cuttings
OSPAR Recommendation 2006/5 on a Management
Regime for Offshore Cuttings Piles.
The Merchant Shipping (Prevention of Oil Pollution)
Regulations 1996 (as amended 2000)
Merchant Shipping Act 1995
International Convention for the Prevention of
Pollution from Ships (MARPOL) 73/78
obliged to implement any Decisions and Recommendations made by the Commissions. Certain decisions made under the earlier Paris Convention also still stand.
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)
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.
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
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
granted by the national competent authority for geological or safety reasons.
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 ShipSource Pollution Directive) Regulations 2009 described above. They address oily drainage from machinery spaces on vessels and installations. The North Sea is designated a
“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
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
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
applied to offshore platforms:
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
Emission Standard for Platforms
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
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.
The REACH Enforcement Regulations 2008
These enforce Regulation (EC) No 1907/2006 of the European Parliament and of the Council concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals
(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.
DECC, Marine
Scotland, CEFAS
The Offshore Petroleum Activities (Oil Pollution
Prevention and Control) Regulations 2005 (as
amended)
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.
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
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
discharges from offshore installations.
 An assessment of BAT and BEP.
 Oil treatment process and operations description.
 Relevant schematic/ process diagrams.
 Drainage sampling feasibility study.
 Produced water meter uncertainty report.
 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).
 Machinery space discharges regulated under.
 Domestic wastes.
 Incidents resulting in a release of oil to sea.
A.9: Territorial Waters
Regulatory Body
Legislation
Hydrographic Office
Territorial Sea Act 1987
Territorial Waters Order
Defines the extent of the territorial sea adjacent to the British Islands.
BMT Cordah Limited
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A.10: Ballast water
Regulatory Body
Legislation
MCA
International Convention for the Control and
Management of Ships' Ballast Water and Sediments
(BWM) – adopted 2004
Objective to prevent, minimise and ultimately eliminate the transfer of harmful aquatic organisms and pathogens though control and management of ships’ ballast water and
sediments. Helsinki and OSPAR Commissions General Guidance on the Voluntary Interim has set out an application of the D1 Ballast Water Exchange Standard.
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
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
MCA
International Convention for the Prevention of
Pollution from Ships (MARPOL) 1973 Annex V, as
amended 1978
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
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.
The dumping of plastics at sea is also prohibited by this Annex.
Environmental Protection Act 1990
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
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.
EA / SEPA
Directive 2008/98/EC of the European Parliament and
of the Council of 19 November 2008 on waste and
repealing certain Directives.
The Waste (Scotland) Regulations 2011
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
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 such use.
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)
Regulations 1991
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
waste is handled lawfully and safely. Special/Hazardous Waste is a sub-category of Controlled Waste (see also Special Waste Regulations).
SEPA
The Controlled Waste Regulations 1992 (as amended
1993)
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
onshore, the wastes must meet the requirements of onshore legislation when being disposed of. These regulations must therefore be considered offshore to allow onshore
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.
DECC
Food and Environment Protection Act 1985
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
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.
The Merchant Shipping (Implementation of ShipSource Pollution Directive) Regulations 2009
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
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
(MARPOL 73), as modified by the Protocol of 1978 (MARPOL 73/78).
The Merchant Shipping (Prevention of Pollution by
Sewage and Garbage from Ships) Regulations 2008
(as amended)
These Regulations implement the requirements of MARPOL 73/78 Annex IV in the UK.
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
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
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.
DECC / MCA
The Special Waste Regulations 1996 as amended
2001, 2012)
The Special Waste (Scotland) Regulations 2004
SEPA
The Waste (Scotland) Regulations 2012 (draft
legislation)
SEPA
BMT Cordah Limited
The Waste Electrical and Electronic Equipment
Regulations 2006 (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
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
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
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 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 Regulations define new responsibilities for users and producers of Electrical and Electronic Equipment depending on whether the equipment was purchased before or after
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
Radioactive Substances Act 1993
The Environmental Permitting (England and Wales)
Regulations 2012
Onshore and offshore storage and disposal of naturally occurring radioactive materials (NORM) is regulated under the Radioactive Substances Act. Operators are required to hold,
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.
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
radioactive waste requires authorisation.
The Radioactive Substances Act 1993 Amendment
(Scotland) Regulations 2011
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
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.
Legislation
SEPA
A.13: Licensing
Regulatory Body
DECC
Petroleum Act, 1998 (as amended by the Energy Act
2008)
The Petroleum Licensing (Exploration and Production)
(Seaward and Landward Areas) Regulations 2004 (as
amended 2006)
The Petroleum Licensing (Production) (Seaward
Areas) Regulations 2008
Marine Licensing (Exempted Activities) (Scottish
Inshore and Offshore Regions) Amendment Order
2012
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
and landward areas below the low water line.
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
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.
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
licence area. Consent to flare or vent hydrocarbons is also required from DECC under the terms of the Model Clauses incorporated into Production Licences.
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
officer.
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.
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
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
DECC
Convention on Environmental Impact Assessment in a
Transboundary Context (Espoo, 1991) (as amended
2004)
The 1991 UNECE Convention on Environmental Impact Assessment in a Transboundary Context (the Espoo Convention) requires any country that has ratified the convention to
consider the transboundary environmental effects of industrial projects and activities, including offshore hydrocarbon exploration activities.
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
DECC
Legislation
Energy Act 2008 (Part 4a)
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
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.
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)
(Consolidation) Order 2000
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
United Kingdom with respect to the sea bed and subsoil and their natural resources are exercisable.
Marine and Coastal Access Act 2009 and Marine
(Scotland) Act 2010
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
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
DECC
OSPAR Recommendation 2003/5 to Promote the Use
and Implementation of Environmental Management
Systems by the Offshore Industry
All Operators controlling the operation of offshore installations on the UKCS are required to have in place an independently verified Environmental Management System designed
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
adverse effects of offshore activities and to demonstrate continual improvement in environmental performance. OSPAR recognises the ISO 14001: 2004 & EMS international
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
DECC, MMO , Marine
Scotland
BMT Cordah Limited
Legislation
Petroleum Act 1998
The Petroleum Act 1998 sets out requirements for undertaking decommissioning of offshore installations and pipelines including preparation and submission of a Decommissioning
Programme.
Energy Act 2008
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
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.
Marine (Scotland) Act 2010
Marine and Coastal Access Act 2009
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
(navigation). FEPA Part II remains in force in Scottish territorial waters to cover reserved activities (within 3 nm).
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
Offshore Installations
Decision that requires operators to remove the whole installation. However large structures are possible exceptions from derogation.
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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
Aqueous discharges
from drilling rig
 Slight deterioration in seawater quality around point of
discharge.
 Potential effects on marine fauna inhabiting the upper
water column (plankton, fish and marine mammals).
 Non-hazardous drains, by their design, discharge only non-hazardous
rainwater which may be slightly contaminated with oily deposits.
 Access points for non-hazardous deck drains are controlled, so any
spillages on deck will not enter the drainage system, but will be cleaned up.
 Non-hazardous drains are designed to take storm and rain water run-offs
from the decks.
 Any possible deterioration of water quality will be short-term.
 The permitted discharge of low volumes of fluids will be dispersed in the offshore
environment and there will be no cumulative or transboundary effects.
 Any possible effects on water quality and marine fauna inhabiting the upper water
column (plankton, fish and marine mammals) will therefore be confined to the immediate
vicinity of the discharge point.
Discharge of sewage
and macerated waste
 Localised increase in biological oxygen demand (BOD)
around the point of discharge (caused by bacterial
degradation of the sewage).
 Input of organic nutrients results in localised increase in
productivity in fish, plankton and micro-organisms.
 Slight deterioration in seawater quality around point of
discharge.
 Sewage will be treated prior to disposal at sea, or contained and shipped to
shore.
 Vessels will be audited to ensure compliance.
 Food waste will be macerated as required by MARPOL and The Merchant
Shipping (Prevention of Pollution by Sewage and Garbage from Ships)
Regulations 2008; this will aid its dispersal and decomposition in the water
column.
 Sewage and macerated food waste (organic material only) will be broken down and
readily dispersed in the offshore environment.
 The particles of food waste will be <25 mm in diameter, and will be rapidly and widely
dispersed in the water column offshore.
 Total quantities discharged over the proposed drilling programme from the rig will be
small in relation to other natural and anthropogenic sources of nutrient enrichment.
Skip and ship of
LTOBM cuttings
 Transportation of cuttings to shore will add to the use of
landfill disposal facilities for their treatment which will
contribute to slight deterioration of air quality.
 All cuttings will be contained and shipped to shore for reprocessing at a
licensed landfill site.
 Transfer operations will be governed by loading and unloading procedures.
 The cuttings will be stored in covered skips to minimise emissions and risk
of spill.
 All LTOBM mud and cuttings will be contained and will therefore present no risk to the
marine environment.
 Onshore treatment and disposal of LTOBM will have a negligible effect on the existing
onshore facilities and infrastructure.
Onshore disposal of
solid waste( rig
&vessels)
 The treatment and disposal of solid wastes at onshore
waste treatment and landfill sites could result in impacts
to the air quality, hydrology, flora and fauna, and
socioeconomic aspects of such sites.
 Waste generation will be minimised.
 All waste will be segregated to allow maximum reuse/recycling. The waste
will be contained, then shipped to shore for recycling or disposal by a
licensed company in full compliance with UK waste legislation and Duty of
Care.
 Use of designated licensed onshore waste disposal / transfer /handling
facilities only.
 Auditing of waste management contractor to ensure compliance.
 Documentation will be in place to ensure that contractors segregate, store, transport,
treat and dispose of waste in accordance with all relevant regulations and Suncor’s
requirements.
Permitted discharge of
drill chemicals
 Some associated deterioration of water quality.
 Potential effect on plankton, fish, shellfish and marine
mammals.
 All chemicals will be risk-assessed and presented in the appropriate permit/
application for statutory approval from the DECC.
 Chemicals will be selected in order to minimise hazards to the environment
in accordance with Offshore Chemicals Regulations 2002 (as amended).
 Chemicals will have been approved by the DECC and risk assessments will indicate the
potential for any environmental impact.
 Discharges will be rapidly dispersed and diluted in the offshore environment and will not
be expected to significantly impact the benthos, water column, fish or marine mammals.
 The quantity used will be minimised as far as practicable.
 Accurate accounting for all casing and flow line sections (which have
individual test certificates and records) and major items of equipment.
 Adherence to lifting and handling procedures and use of certified equipment
for lifting.
 Requirement to retrieve major items of debris from the seabed after
operations, in compliance with relevant legislation.
 Major items will be recovered from the seabed, therefore no long-term impact would be
anticipated.
 Loss of individual hand-tools and other minor items of equipment will not constitute a
threat to species, habitats or fishing.
Drilling: Unplanned events
Objects dropped into
the sea
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 Disturbance to the seabed, water quality and benthos.
 Potential obstruction to commercial fishing and other
commercial users of the sea.
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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
 Post-decommissioning a debris survey will be undertaken to remove any
objects remaining on the seabed.
 The area of seabed that will be disturbed as a result of decommissioning activities will
be localised and very small. Re-colonisation will occur after operations have ceased.
 Any possible deterioration of water quality will be rapidly dispersed and diluted.
 All impacts will be temporary not permanent.
Decommissioning: Planned events
Discharge of sewage
and macerated waste
 Refer to Table B1
Plug and
abandonment of wells
 Potential for temporary deterioration of water quality and
effects on plankton
 Disturbance to sediments and potential for debris to
remain on the seabed.
 Temporary alteration of sediment structure and
smothering of seabed organisms.
Decommissioning: Unplanned events
Objects dropped into
the sea
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 Refer to Table B1
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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 O 3 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
Activity
Emissions (t)
CO2
CO
NOx
N2O
SO2
CH4
VOC
Total
Total emissions
from UKCS
offshore
exploration and
production
activities during
2010
16,393,119
24,649
55,837
1,006
2,628
50,476
54,050
16,581,765
Total GWP
emissions from
UKCS offshore
exploration and
production
activities during
2010*
16,393,119
73,947
279,185
297,776
-
1,160,948
-
18,204,975
*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
Activity
Days
Fuel consumption
t/day
tonnes
Marine diesel factors (tonne/ tonne)
Emissions (tonnes)
CO2
CO
NOx
N2O
SO2
CH4
VOC
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
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
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
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
4,440.00
11.10
81.86
0.31
5.55
0.37
3.33
Jack-up drilling rig
Standby vessel
Supply vessel
Total emissions from drilling operations
Source: Marine diesel factors from Oil and Gas UK (2012)
Table C.3: Estimated gaseous emissions from helicopter operations
Activity
hours
Fuel consumption
t/day
tonnes
Aviation fuel factors (tonne/ tonne)
Emissions (tonnes)
CO2
CO
NOx
N2O
SO2
CH4
VOC
3.2
0.0052
0.0125
0.00022
0.004
0.000087
0.0008
50.21
0.08
0.20
0.00
0.06
0.00
0.01
50.21
0.08
0.20
0.00
0.06
0.00
0.01
Helicopter flights to jack-up drilling rig
Helicopter flights*
30
0.523
15.69
Total emissions from helicopter operations
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
Activity
Emissions (t)*
CO2
CO
NOx
N2O
SO2
CH4
VOC
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
Activity
GWP emissions (t)*
CO2
CO
NOx
N2O
SO2
CH4
VOC
Total GWP**
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
operations
4,490.21
33.54
410.30
91.76
-
8.51
-
5,034.32
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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
Protected Area
Designation
Marine
Protected Area
(MPA)
International
or National
Designation
National
Statutory
protection
or other
Statutory
Present in Moray
Firth or Assessed
Coastline
Yes
Purpose
Other Information
MPAs are recognised globally as one way to support our marine
environment. A well-managed network of MPAs will protect important
marine habitats and species, deliver benefits for our marine
environments, support coastal communities, help sustain marine
industries and provide for recreational uses (SNH, 2014c).
On the 24th July 2014, Scottish Ministers designated 30 Nature
Conservation Marine Protected Areas to conserve some of
Scotland's most important marine wildlife, habitats and
geodiversity, of which 13 are offshore MPAs. Covering over 10%
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).
There are currently 47 promoted National Nature Reserves in
Scotland. These special places, showcasing the very best of
Scotland's nature, cover less than 1.5% of Scotland (SNH,
2014d).
National Nature
Reserves
(NNR)
National
Statutory
Yes
NNRs contain examples of some of the most important natural and
semi-natural terrestrial and coastal ecosystems in Great Britain.
They are managed to conserve their habitats or to provide special
opportunities for scientific study of the habitats communities and
species represented within them (JNCC, 2014c).
National Parks
National
Statutory
No
The purpose of National Parks is to conserve and enhance
landscapes within the countryside whilst promoting public enjoyment
of them and having regard for the social and economic well-being of
those living within them.
There are two national parks in Scotland - Loch Lomond and The
Trossachs, established in 2002, and the Cairngorms, established
in 2003.
Natura 2000 is the name of the European Union-wide network of
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
Natura 2000 sites contribute to our ecologically coherent network of
marine protected areas.
Not applicable
The RAMSAR Convention's mission is "the conservation and wise
use of all wetlands through local and national actions and
international cooperation, as a contribution towards achieving
sustainable development throughout the world" (RAMSAR, 2014).
There are currently 51 RAMSAR sites designated as
internationally important wetlands in Scotland, covering a total
area of about 313,000 hectares.
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).
NATURA 2000
*RAMSAR
International
International
BMT Cordah Limited
Not
applicable
Statutory
Not applicable
Yes
D-5
November 2014
Statement
W/4171/2014
Table D.1 (continued): National and international conservation designations
Protected Area
Designation
Site of Special
Scientific
Interest (SSSI)
Special Area of
Conservation
(SAC)
Special
Protected Area
(SPA)
World Heritage
Sites
International
or National
Designation
National
International
International
International
BMT Cordah Limited
Statutory
protection
or other
Statutory
Statutory
Statutory
Statutory
Present in Moray
Firth or Assessed
Coastline
Purpose
Other Information
Please see entry for RAMSAR sites above.
Yes
Sites of Special Scientific Interest (SSSI) are those areas of land and
water (to the seaward limits of local authority areas) that Scottish
Natural Heritage (SNH) considers to best represent our natural
heritage - its diversity of plants, animals and habitats, rocks and
landforms, or a combinations of such natural features.
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).
Yes
SACs are designated under the EC Habitats Directive. The Directive
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
listed on Annexes I and II of the Directive. SACs in terrestrial areas
and territorial marine waters out to 12 nautical miles are designated
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).
Yes
SPAs are classified by the UK Government under the EC Birds
Directive. The Directive applies to the UK and the overseas territory
of Gibraltar. SPAs are areas of the most important habitat for rare
(listed on Annex I of the Directive) and migratory birds within the
European Union. SPAs in terrestrial areas and territorial marine
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).
Scotland has one natural world heritage site, also our only joint
natural and cultural world heritage site - the islands of St Kilda
(JNCC, 2014c).
No
World Heritage Sites are designated to meet the UK's commitments
under the World Heritage Convention. The UK's ratification of the
Convention also extends to its Overseas Territories and Crown
Dependencies. These sites are designated for their globally
important cultural or natural interest and require appropriate
management and protection measures. Natural properties may be
terrestrial or marine areas (JNCC, 2014c).
D-6
November 2014
Statement
W/4171/2014
Protected Area
Designation
Special
Landscape
Areas
Biogenetic
Reserves
Biosphere
Reserves
Geological
Conservation
Review (GCR)
Sites
International
or National
Designation
National
Statutory
protection
or other
Local
Authority
International
Nonstatutory
International
Nonstatutory
National
BMT Cordah Limited
Statutory
and Nonstatutory
Present in Moray
Firth or Assessed
Coastline
Purpose
Other Information
Yes
There are many areas where the scenery is highly valued locally,
and local authorities often give these landscapes a local designation.
This is to ensure that the landscape is not damaged by inappropriate
development, and in some cases encourage positive landscape
management. These designations play an important role in
developing an awareness of the landscape qualities that make
particular areas distinctive, and promote a communities sense of
pride in their surroundings.
Local landscape designations are shown in local development
plans, and have associated policies to safeguard their valued
features.
Scottish Natural Heritage and Historic Scotland have now jointly
published guidance to assist local authorities to refresh their
approach to landscape designations.
Biogenetic Reserves were first established to accommodate
biological research. Their purpose has since been overtaken by
that of Scotland's national nature reserve network.
Yes
Biogenetic Reserves act as 'living laboratories' and are
representative examples of various types of natural environment in
Europe. They can consist of natural or semi-natural habitats and
their selection is based on their value for nature conservation and
protected status based on four criteria: 'typical', 'unique', 'rare' and/
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).
No
Biosphere Reserves are areas of terrestrial and coastal ecosystems
promoting the conservation of biodiversity with sustainable use.
Biosphere reserves serve to demonstrate integrated management of
land, water and biodiversity.
Currently there are two biosphere reserves in Scotland :

Beinn Eighe, in Wester Ross.

Galloway and Southern Ayrshire Biosphere Reserve
external site.
Designation of geological and geomorphological features in Sites of
Special Scientific Interest (SSSIs) is underpinned by the Geological
Conservation Review (GCR). The GCR, undertaken by the Joint
Nature Conservation Committee (JNCC), selected the very best and
most representative geological and geomorphological features of
Britain.
There are currently (June 2012) 895 GCR sites in Scotland.
Of these, 204 (23%) have no protective Site of Special Scientific
Interest (SSSI) designation status. These are termed 'unnotified
GCR sites'.
Significant areas of a further 28 sites (3%) also have no
protective SSSI designation status. National Park Authorities and
some Local Authorities treat these unnotified GCR sites as
candidate SSSIs and afford them the same protection.
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.
Not applicable
D-7
November 2014
Statement
W/4171/2014
Protected Area
Designation
Geoparks
National Scenic
Area (NSA)
International
or National
Designation
Statutory
protection
or other
International
Nonstatutory
National
Nonstatutory
Present in Moray
Firth or Assessed
Coastline
Purpose
Other Information
In Scotland there are 3 UNESCO European Geoparks, in the
North West Highlands, Lochaber and Shetland.
No
A Geopark is a territory, which includes a particular geological
heritage and a sustainable territorial development strategy supported
by a European programme to promote development.
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
to identify our finest scenery and to ensure it is protected from
inappropriate development. This is achieved through the local
authority planning system.
There are 40 NSAs in Scotland, with their outstanding scenery,
represent Scotland's finest landscapes. They include spectacular
mountain areas such as the Skye Cuillins, Ben Nevis and
Glencoe, and dramatic island landscapes within the Hebrides and
the Northern Isles.
Yes
*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.
BMT Cordah Limited
D-8
November 2014
W/4171/2014
Figure D.2a: Offshore, inshore and terrestrial forms of conservation designation associated with the Niobe Exploration Well
BMT Cordah Limited
D-9
November 2014
W/4171/2014
Figure D.2b: Offshore, inshore and terrestrial forms of conservation designation associated with the Niobe Exploration Well
BMT Cordah Limited
D-10
November 2014
W/4171/2014
Table D.2: Conservation sites within the Moray Firth and along the Moray Firth
coastline
Site Name
Location
Protected features / conservation interest(s)
Figure/ inset
reference
Marine Protected Areas (MPAs)
East Caithness
Cliffs
Territorial waters
Black guillemot (Cepphus grille)
Figure C.2a;
Inset A
Noss Head
Territorial waters
Horse mussel beds
Figure C.2a;
Inset A
Firth of Forth
Banks Complex
Offshore




Figure C.2b;
Inset B
Wyre and Rousay
Sounds
Territorial waters
 Kelp and seaweed communities on sublittoral sediment
 Maerl beds
 Marine geomorphology of the Scottish Shelf Seabed
Figure C.2b;
Inset A
Northwest Orkney
Offshore
 Sandeel
 Sand banks, sand wave fields and sediment wave
fields
Figure C.2b;
Inset B
Ocean quahog aggregations
Offshore subtidal sands and gravels
Shelf banks and mounds
Moraines
Special Areas of Conservation (SAC)
East Caithness
Cliffs
Terrestrial
 Vegetated sea cliffs
Figure C.2a;
Inset A
Moray Firth
Territorial waters
and offshore area
 Subtidal sandbanks
 Bottlenose dolphin
Figure C.2a;
Inset B
Dornoch Firth and
Morrich More
Territorial waters







Figure C.2a;
Inset B
Reefs
Subtidal sandbanks
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
 Shifting dunes
 Coastal shingle vegetation outside the reach of waves
Figure C.2a;
Inset B
Lower River Spey
– Spey Bay
Territorial waters
 Alder woodland on floodplains
 Coastal shingle vegetation outside the reach of waves
Figure C.2a;
Inset B
River spey
Terrestrial




Figure C.2a;
Inset B
Buchan Ness to
Collieston Coast
Terrestrial
 Vegetated sea cliffs
Figure C.2b;
Inset B
Sanday
Territorial waters




Reefs
Subtidal sandbanks
Intertidal mudflats and sandflats
Harbour seal
Figure C.2b;
Inset A
Sands of Forvie
Terrestrial




Lime-deficient dune heathland with crowberry
Humid dune slacks
Shifting dunes
Shifting dunes with marram
Figure C.2b;
Inset B
BMT Cordah Limited
Sea lamprey (Petromyzon marinus)
Atlantic salmon (Salmo salar)
Otter
Freshwater pearl mussel (Margaritifera margaritifera)
D-11
November 2014
W/4171/2014
Figure/ inset
reference
Site Name
Location
Garron Point
Terrestrial
 Narrow-mouthed whorl snail (Vertigo angustior)
Figure C.2b;
Inset B
Special Protected Areas (SPAs)
East Caithness
Cliffs
Terrestrial











Cormorant, breeding
Guillemot, breeding
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
Figure C.2a;
Inset A
North Caithness
Cliffs
Terrestrial







Peregrine, breeding
Fulmar, breeding
Guillemot, breeding
Kittiwake, breeding
Razorbill, breeding
Puffin, breeding
Figure C.2a;
Inset A
Dornoch Firth and
Loch Fleet
Territorial waters









Osprey (Pandion haliaetus), breeding
Waterfowl assemblage, non-breeding
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
Figure C.2a;
Inset A
Inner Moray Firth
Territorial waters















Common Tern, breeding
Osprey, breeding
Goldeneye, non-breeding
Redshank, non-breeding
Goosander (Mergus merganser), non-breeding
Teal, non-breeding
Red-breasted Merganser, non-breeding
Cormorant, non-breeding
Oystercatcher, non-breeding
Scaup (Aythya marila), non-breeding
Figure C.2a;
Inset A
Moray and Nairn
Coast
Terrestrial








Osprey, breeding
Common Scoter (Melanitta nigra), non-breeding
Long-tailed Duck (Clangula hyemalis), non-breeding
Oystercatcher , non-breeding
Pink-footed Goose, non-breeding
Red-breasted Merganser, non-breeding
Figure C.2a;
Inset A
BMT Cordah Limited
D-12
November 2014
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Site Name
Location





Velvet Scoter (Melanitta fusca), non-breeding
Dunlin, non-breeding
Figure/ inset
reference
Troup, Pennan
and Lion's Heads
Terrestrial






Razorbill, breeding
Fulmar, breeding
Guillemot, breeding
Kittiwake, breeding
Herring gull, breeding
Figure C.2a;
Inset C
Loch of Strathbeg
Terrestrial







Sandwich Tern, breeding
Teal, non-breeding
Svalbard Barnacle Goose, non-breeding
Whooper Swan, non-breeding
Figure C.2a;
Inset C
Buchan Ness to
Collieston Coast
Terrestrial






Kittiwake, breeding
Shag, breeding
Fulmar, breeding
Guillemot, breeding
Herring Gull, breeding
Figure C.2b;
Inset B
Ythan Estuary,
Sands of Forvie
and Meikle Loch
Terrestrial








Common Tern, breeding
Little Tern, breeding
Sandwich Tern, breeding
Lapwing (Vanellus vanellus), non-breeding
Eider, non-breeding
Figure C.2b;
Inset B
Fowlsheugh
Terrestrial






Fulmar, breeding
Guillemot, breeding
Kittiwake, breeding
Razorbill, breeding
Herring Gull, breeding
Figure C.2b;
Inset B
Pentland Firth
Islands
Territorial waters
 Arctic Tern, breeding
Figure C.2b;
Inset A
Auskerry
Territorial waters
 Storm Petrel, breeding
Figure C.2b;
Inset A
East Sanday
Coast
Territorial waters
 Turnstone, non-breeding
 Purple Sandpiper, non-breeding
 Bar-tailed Godwit, non-breeding
Figure C.2b;
Inset A






Figure C.2a;
Inset A
Sites of Special Scientific Areas (SSSIs)
Duncansby Head
Terrestrial
BMT Cordah Limited
Fulmar (Fulmarus glacialis)
breeding Kittiwake (Rissa tridactyla)
Seabird colony, breeding
Guillemot (Uria aalge), breeding
Geomorphology of Scotland
Maritime cliff
D-13
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Figure/ inset
reference
Site Name
Location
Castle of Old
Wick to Craig
Hammel
Terrestrial
 Maritime cliff
Figure C.2a;
Inset A
Craig Hammel to
Sgaps Geo
Terrestrial





Figure C.2a;
Inset A
Dunbeath to
Sgaps Geo
Terrestrial
 Maritime cliff
Figure C.2a;
Inset A
Berriedale Cliffs
Terrestrial







Figure C.2a;
Inset A
Ousdale Burn
Terrestrial
 Upland birch woodland
Figure C.2a;
Inset A
Helmsdale Coast
Terrestrial
 Mesozoic Palaeobotany
 Kimmeridgian
Figure C.2a;
Inset A
Inverbrora
Terrestrial




Figure C.2a;
Inset B
Dunrobin Coast
Terrestrial
 Hettangian, Sinemurian, Pliensbachian
Figure C.2a;
Inset B
Loch Fleet
Terrestrial








Eider (Somateria mollissima), non-breeding
Breeding bird assemblage
Native pinewood
Saltmarsh
Eelgrass beds
Sand flats
Sand dunes
Vascular plant assemblage
Figure C.2a;
Inset B
Dornoch Firth
Terrestrial







Whooper Swan (Cygnus cygnus), non-breeding
Wigeon (Anas penelope), non-breeding
Bar-tailed Godwit (Limosa lapponica), non-breeding
Saltmarsh
Eelgrass beds
Sand dunes
Figure C.2a;
Inset B
Morrich More
Terrestrial










Teal (Anas crecca), non-breeding
Curlew (Numenius arquata), non-breeding
Coastal Geomorphology of Scotland
Saltmarsh
Invertebrate assemblage
Sand dunes
Figure C.2a;
Inset B
BMT Cordah Limited
Razorbill (Alca torda), breeding
Guillemot, breeding
Maritime cliff
Fulmar , breeding
Razorbill , breeding
Guillemot, breeding
Shag (Phalacrocorax aristotelis), breeding
Maritime cliff
Mesozoic Palaeobotany
Bathonian
Callovian
Oxfordian
D-14
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Figure/ inset
reference
Site Name
Location
Tarbat Ness
Terrestrial
 Coastal Geomorphology of Scotland
 Non-marine Devonian
 Maritime Cliff
Figure C.2a;
Inset B
Rosemarkie to
Shandwick Coast
Terrestrial








Notified feature
Upland birch woodland
Mesozoic Palaeobotany
Callovian
Moine
Maritime cliff
Sand dunes
Purple Oxytropis (Oxytropis halleri)
Figure C.2a;
Inset B
Munlochy Bay
Terrestrial




Greylag Goose (Anser anser), non-breeding
Saltmarsh
Mudflats
Figure C.2a;
Inset B
Longman and
Castle Stuart
Bays
Terrestrial





Goldeneye (Bucephala clangula), non-breeding
Redshank (Tringa totanus), non-breeding
Cormorant (Phalacrocorax carbo), non-breeding
Red-breasted Merganser (Mergus serrator), nonbreeding
 Saltmarsh
 Eelgrass beds
 Mudflats
Figure C.2a;
Inset B
Whiteness Head
Terrestrial







Knot (Calidris canutus), non-breeding
Saltmarsh
Sandflats
Sand dunes
Shingle
Figure C.2a;
Inset B
Culbin Sands,
Culbin Forest and
Findhorn Bay
Terrestrial










Hydromorphological mire range
Fungi assemblage
Lichen assemblage
Saltmarsh
Invertebrate assemblage
Mesotrophic loch
Shingle
Sand dunes
Figure C.2a;
Inset B
Masonshaugh
Terrestrial
 Permian - Triassic Reptilia
 Permian Triassic (red beds)
Figure C.2a;
Inset B
Clashach –
Covesea
Terrestrial
 Permian - Triassic Reptilia
Figure C.2a;
Inset B
Lossiemouth
Shore
Terrestrial
Figure C.2a;
Inset B
Spey Bay
Terrestrial






Figure C.2a;
Inset B
BMT Cordah Limited
Wet woodland
Small blue (Cupido minimus)
Dingy Skipper (Erynnis tages)
Hydromorphological mire range
Saltmarsh
D-15
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Site Name
Location
Figure/ inset
reference
 Shingle
 Vascular plant assemblage
Cullen to Stake
Ness Coast
Terrestrial






Whitehills to
Melrose Coast
Terrestrial
 Dalradian
Figure C.2a;
Inset B
Gamrie and
Pennan Coast
Terrestrial










Guillemot, breeding
Kittiwake, breeding
Razorbill, breeding
Puffin (Fratercula arctica), breeding
Fulmar, breeding
Gannet (Morus bassanus), breeding
Quaternary of Scotland
Dalradian
Maritime cliff
Figure C.2a;
Inset C
Rosehearty to
Fraserburgh
Coast
Terrestrial





Purple Sandpiper (Calidris maritima), non-breeding
Turnstone (Arenaria interpres), non-breeding
Eider (Somateria mollissima), non-breeding
Dalradian
Figure C.2a;
Inset C
Cairnbulg to St
Combs Coast
Terrestrial
 Dalradian
Figure C.2a;
Inset C
Loch of Strathbeg
Terrestrial




Figure C.2a;
Inset C






Lowland dry heath
Springs (including flushes)
Saltmarsh
Quaternary of Scotland
Dalradian
Shingle
Goldeneye, non-breeding
Whooper Swan, non-breeding
Pink-footed Goose (Anser brachyrhynchus), nonbreeding
Fen meadow
Open water transition fen
Saltmarsh
Eutrophic loch
Figure C.2a;
Inset B
Pentland Firth
Islands
Territorial waters
 Arctic Tern (Sterna paradisaea), breeding
 Vascular plant assemblage
Figure C.2b;
Inset A
Ward Hill Cliffs
Terrestrial
 Maritime cliff
Figure C.2b;
Inset A
Copinsay
Territorial waters
 Guillemot, breeding
 Seabird colony, breeding
 Kittiwake (Rissa tridactyla), breeding
Figure C.2b;
Inset A
Auskerry
Territorial waters
 Storm Petrel (Hydrobates pelagicus), breeding
Figure C.2b;
Inset A
East Sanday
Coast
Territorial waters






Figure C.2b;
Inset A
BMT Cordah Limited
Purple Sandpiper , non-breeding
Sanderling (Calidris alba), non-breeding
Ringed Plover (Charadrius hiaticula), non-breeding
Turnstone, passage
Turnstone, non-breeding
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Site Name
Location




Rocky shore
Sand flats
Harbour seal
Figure/ inset
reference
Central Sanday
Terrestrial




Saltmarsh
Machair
Sand dunes
Figure C.2b;
Inset A
Sands of Forvie
and Ythan
Estuary
Terrestrial












Common Tern (Sterna hirundo), breeding
Eider, breeding
Little Tern (Sternula albifrons), breeding
Arctic Tern, breeding
Sandwich Tern (Sterna sandvicensis), breeding
Eider, non-breeding
Saltmarsh
Sand dunes
Figure C.2b;
Inset B
Foveran Links
Terrestrial
 Coastal Geomorphology of Scotland
 Sand dunes
Figure C.2b;
Inset B
Cove
Terrestrial
 Maritime cliff
 Dickie's bladder-fern (Cystopteris dickieana)
Figure C.2b;
Inset B
Garron Point
Terrestrial






Northern brown argus (Aricia artaxerxes)
Ordovician Igneous
Narrow-mouthed whorl snail (Vertigo angustior)
Silurian - Devonian Chordata
Dalradian
Maritime cliff
Figure C.2b;
Inset B
St Cyrus and
Kinnaber Links
Terrestrial








Small blue
Saltmarsh
Lowland neutral grassland
Moths
Shingle
Sand dunes
Figure C.2b;
Inset B
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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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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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Niobe Exploration Well Environmental Statement

Transcription

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