Post Consent Monitoring –guiding principles - some key

questions?

Steve Bellew, Director

• Points to bear in mind

• The regulatory framework

• Monitoring first principles – why and where?

• Strategic monitoring – opportunities and constraints?

• Monitoring first principles – what?

• Monitoring first principles – how?

• Summary – a few questions to keep in mind?

Overview

• The UK needs a lot of new electricity generating infrastructure (up to £100billion by 2020 – offshore wind up to £21.3billion)

• CfD context – cost of energy is key driver

• Reduction in regulatory burden – key Government policy

But

• Need to prepare for future OWF licensing and assessment – increase regulatory certainty on key issues (and reduce precaution in decision making)

• Need to protect the environment

Points to bear in mind

The regulatory framework

• Marine licensing process

• Follows an EIA process and consent determination

• Marine planning and NPS context

• Worst case scenario (rochdale envelope) consents

• Monitoring in licensing context (‘regulatory’) vs monitoring for broader knowledge base (‘research’)?

• Open ended (vague) marine licence conditions – what should they be trying to achieve?

Monitoring first principles – why and where?

• Main Drivers for (‘regulatory’) monitoring?

• EIA significance?

• Significant uncertainty?

• Regulatory compliance (conditions/mitigation)?

• Validate EIA conclusions?

• Detect unforeseen impacts?

• Scale - what is an appropriate spatial or organisational hierarchy for addressing monitoring requirements (‘regulatory’ and ‘research’?)

• How do we prioritise and organise monitoring (or research) priorities at different scales?

Project/Site Specific Monitoring (regulatory) E.g. seabed debris? Annex I habitats?

Regional / zonal level monitoring (regulatory – research) E.g. regional or Natura 2000 site populations? Representative studies for specific or less important uncertainties?

Industry – government wide studies (research – interest) E.g. Generic research on OWF (of academic interest or non-project specific importance)?

A monitoring hierarchy?

Strategic monitoring – opportunities and constraints?

• What benefits accrue from a more co-ordinated/strategic approach?

• What are the possible models for a ‘strategic’ approach within the licensing framework?

• How does the marine licensing and enforcement process affect flexibility in monitoring and strategic approaches?

• How do you manage differences in individual project programs (consent compliance; funding etc)?

• How do you cope with the outputs of a strategic monitoring program (enforcement)?

• Administration, roles, responsibilities and funding?

Monitoring Programme (offshore)

Benthic survey

Non-native species assessment

Swath-bathymetry/side scan sonar survey(s)

Ornithological activity survey

Information gathering of elasmobranch

populations/EMF impacts

Marine Mammal activity survey

Traffic monitoring

Bathymetry/side scan sonar survey(s) after major storm

event

Traffic monitoring (navigation monitoring strategy)

Pre-construction WSI Construction Post-construction

Benthic survey

Annex 1 Habitat survey

Swath-bathymetry/side scan sonar survey(s)

(debris)

Ornithological activity survey

Information gathering of elasmobranch populations/EMF

impacts

Marine Mammal activity survey

Noise monitoring • Responsibilities • Site investigation

methodology • Analysis/reporting of

survey data • Mitigation/AEZ • Pre/post construction

monitoring • Archiving protocol • Reporting/recording

protocol

Monitoring first principles – what?

What to monitor – a question of risk?

• Monitoring (measuring?) everything - everywhere - always – should we expect to do that? What can it achieve? Is it justified?

• What are the (regulatory) risks of not doing that?

• What are the (regulatory) benefits of not doing that?

• And who carries the risks / accrues the benefits?

• How do we decide what to monitor and where?

• Prioritisation process?

• Key issues / drivers for monitoring?

• Applying the ‘So What’ test?

• Adaptive management?

Monitoring first principles – how?

• Broadly worded licence conditions – how to define specific focus for monitoring?

• What is possible and at what cost?

• Limitations?

• Site specific impacts vs in-combination/cumulative impacts

• Strategic or project specific?

• Experimental design:

• Clear hypotheses?

• Statistical power to detect change?

• Ability to attribute causal links?

To sum up – some key questions to keep in mind?

• Cost reduction driver vs need to plan for future rounds and protect

environment?

• Monitoring for ‘regulation’ vs undertaking ‘research’?

• What are the key drivers for undertaking ‘regulatory’ monitoring?

• At what scale should monitoring be organised? Can we develop a

hierarchy to address different issues?

• What are the benefits of and constraints on ‘strategic’ monitoring?

• How do we organise and fund collaborative monitoring and broader

research needs?

• What should be the guiding principles on monitoring design and

conduct?

• How do we balance risk and reward – prioritisation for monitoring

(and research)? Applying the ‘so what’ test?

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