by kowag » Sun Nov 07, 2010 5:13 pm
SSE Shipping study Superficial and flawed, in our opinion:
The Kintyre Offshore Windfarm Action Group has obtained a copy of the study commissioned by Scottish Southern Energy Renewables (SSE) to determine the impact on shipping of the proposed Islay and Kintyre Offshore Windfarms. The study was completed by a company called Anatec and has proved to be less than thorough, so the Action Group has written an open letter to SSE detailing the 8 key defects they can see in the study:
1. The study is based on only 28 days of data (8% sample) but the choice of early January data (when there is virtually nil shipping for 7days of that month due to the hangover from the New Year holidays) artificially reduces the traffic density and associated graphics and misreppresents the real picture. You should repeat the sampling data from end January to provide a more honest sample.
2. It is disappointing that this study focuses entirely on shipping carrying the Automatic Identification System, thus ignoring leisure craft and small fishing vessels. I recognise that Anatec recommend a seperate study (and hope the Government insist SSE undertake this) for such craft, but it would be more meaningful to have the complete picture in one document, otherwise for example you are trying to compare and overlay data across two data sets, diluting conclusions and impacts.
3. The report makes vague allusions to "alternative routes that can be taken without adding significantly to voyage distance" but makes no effort to quantify that or the costs associated with it, despite the fact that in both cases the existing sea lanes and associated medium to high risk zones cover the entirety of the proposed windfarm areas, requiring the sea lanes to be rerouted past them.
4. The generalised assertion that "in many cases there is sea room adjacent to the routes for ships to increase their clearance from a wind farm" is preposterous for the Kintyre site as clearly there is no searoom at all to landward of that inshore site and figure 5.4 shows that moving it to the West would impinge on the Islay route and a submarine exercise area.
5. The submarine exercise area gets no analysis at all except for the almost risible statement that "A good lookout is to be kept for them
when passing through these waters"!! This despite the fact it is the most direct transit route for submarines to Faslane and forcing more shipping into this area of "searoom" is logically a greater risk....though how much of a risk we don't know because it was overlooked by Anatec.
6. It is very disappointing that Anatec's high level recommendations blanket cover both sites - taking no account whatever of their differences and features - this is shoddy and superficial. The Kintyre site is only 0.7 nautical miles offshore compared to 7 miles for the Islay site and they have utterly different ship types using the routes, yet no meaningful differentiation is made.
7. The main recommendation is that this study should be used for windfarm "site optimisation". This wholly ignores the main conclusion that "
Development within the Kintyre site will mean that vessels would not be able to use the sheltered coastal route and would have to re-route further to the West which will bring them closer to the larger vessels using the Northbound lanes of the North Channel TSS as well as increasing there (sic) passage times" and the fact that the study shows 100% of the proposed Kintyre site is covered by shipping lanes and zones of medium to very high risk. The study does not state the blindingly obvious - this proposed windfarm site is in the wrong place and it is not the sea lanes that need rerouting but the windfarm.
8. The proposed stakeholder consultation list is deficient. It does not mention representatives of the fishing industry or local sailing clubs in Scotland and Northern Ireland.
This response was copied to MSP Jim Mather, Minister for Energy who responded that the comments had been noted and passed to the relevant departments to consider. Even this flawed study shows that there will be considerable disruption and possible danger to ships no longer able to use the sheltered coastal route..