SCOTTISH HYDRO ELECTRIC POWER

DISTRIBUTION PLC.
Pentland Firth
Navigational Risk Assessment

P2577_R5880_Rev2 | 21 November 2022

Intertek Energy & Water Consultancy Services

Prospect Business Centre, Dundee Technology Park, Dundee DD2 1TY, United Kingdom
Scottish Hydro Electric Power Distribution plc.
Pentland Firth
Navigational Risk Assessment

DOCUMENT RELEASE FORM

Scottish Hydro Electric Power Distribution plc.

P2577_R5880_Rev2
Pentland Firth
Navigational Risk Assessment

Author/s

Alice Gymer

Project Manager Authoriser

Matthew Peden Eric Houston

Rev No Date Reason Author Checker Authoriser

Rev 0 27/09/2022 Original issue to client AERG CCA APA
Rev 1 07/11/2022 Addressing client comments AERG CCA LH
Rev 2 21/11/2022 Addressing additional client AERG MJP ELH
comments

Intertek Energy & Water Consultancy Services is the trading name of Metoc Ltd, a member of the Intertek group of companies.

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Scottish Hydro Electric Power Distribution plc.
Pentland Firth
Navigational Risk Assessment

CONTENTS

DOCUMENT RELEASE FORM I

GLOSSARY IV

1. SHIPPING AND NAVIGATION 1

1.1 Introduction 1
1.2 Guidance Methodology 4
1.3 Marine Campaign Works 12
1.4 Existing Baseline Assessment 14
1.5 Hazard Identification 26
1.6 Risk Control 26

2. RISK ANALYSIS 28
2.1 Displacement of vessels due to the avoidance of project vessels 28
2.2 Collision Risk 28
2.3 Accidental anchoring on surface laid cable 28
2.4 Accidental snagging of fishing gear on unburied cable 29
2.5 Project vessels blocking navigational features 29
2.6 Extreme weather conditions 29
2.7 Reduced visibility 30
2.8 Change in water depth – affecting safe navigation 30

3. RISK ASSESSMENT 31
3.1 Assessment 31
3.2 Conclusions 33

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LIST OF TABLES AND FIGURES

Tables
Table 1-1 EMODnet Ship Category Descriptions 6
Table 1-2 Applied Grouping of RNLI Data 6
Table 1-3 Frequency of a hazard 9
Table 1-4 Consequence of a hazard 10
Table 1-5 Risk Matrix 10
Table 1-6 Definitions of risk levels with respect to vessel displacement 11
Table 1-7 Marine Operations and Identified Hazards – Shipping and Navigation 26
Table 1-8 Compliance Mitigation 27
Table 1-9 Best Practice Mitigation 27
Table 3-1 NRA Risk Assessment 32

Figures
Figure 1-1 Location overview of Pentland Firth (P2577-LOC-004) 3
Figure 1-2 Assessment Steps 4
Figure 1-3 Vessel Distribution Across the Pentland Firth East Route 15
Figure 1-4 Seasonality Changes in Vessel Traffic Across the Pentland Firth East Route 16
Figure 1-5 EMODnet Shipping Density Across the Proposed Development (P2577-AIS-001) 17
Figure 1-6 Vessel Activity in the Pentland Firth 18
Figure 1-7 Recreational Boating Areas Across the Study Area (P2577-RYA-001) 20
Figure 1-8 Fishing Activity Across the Study Area (P2577-FISH-001) 22
Figure 1-9 RNLI Yearly Callouts 23
Figure 1-10 Recorded Incidents between 2008 and 2020 (P2577-RNLI-001) 24

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GLOSSARY

AIS OOS
Automatic Identification System Out of Service

ALARP PLGR
As Low As Reasonably Practicable Pre-Lay Grapnel Runs

BP RLNI
Best Practice Royal Lifeboat National Institution

CD RYA
Chart Datum Royal Yachting Association

CLV SSEN
Cable Lay Vessel Scottish and Southern Electricity Networks
COLREGs SHEPD
Collision Regulations Scottish Hydro Electric Power Distribution plc
COMP SOLAS
Compliance Safety Of Life At Sea
DP UKHO
Dynamic Positioning United Kingdom Hydrographic Office
FLMAP VMS
Fishing Liaison Mitigation Action Plan Vessel Monitoring System
FLO vhpm
Fishing Liaison Officer Vessel Hours Per Month
KP
Kilometre Point
MAIB
Marine Accident Investigation Branch
MCA
Maritime and Coastguard Agency
MSI
Maritime Safety Information
NM
Nautical Miles
NTM
Notice To Mariners
NRA
Navigational Risk Assessment

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Navigational Risk Assessment

1. SHIPPING AND NAVIGATION

1.1 Introduction
1.1.1 Aim of this Section
This section identifies the potential risk to shipping and navigation arising from cable activities
associated with installation of the replacement cable, decommissioning of the offshore (where
required) and nearshore sections of the existing cable and the presence of the replacement cable
during its operational lifespan.
Where relevant, any limitations related to the baseline conditions, data sources or scientific
understanding / interpretation within the process of assessing the effects have been highlighted.

1.1.2 Data sources

Automatic Identification System (AIS) data from EMODnet covering 2021 have been used in this
section. As per Regulation 19 of Chapter V, Safety of Navigation, of the Annex to the International
Convention for the Safety of Life at Sea (SOLAS V), 1 July 2002, an AIS must be installed and operated
on: all ships of 300 gross tonnage and upwards engaged on international voyages; cargo ships of
greater than 500 gross tonnage not engaged on international voyages; all passenger vessels
irrespective of size and fishing vessels greater than 15 m. In recent years, AIS has increasingly been
installed by other maritime users on smaller craft, including yachts, fishing vessels, and pleasure craft,
making it a robust and reliable indicator of marine traffic.
Baseline conditions for shipping and navigation have been established by undertaking a desktop
review of published information and available reports for the project in relation to shipping, fishing
and navigation. The data sources used to inform the baseline description and assessment include the
following:
▪ AIS data. EMODNET (2021);
▪ Admiralty charts, http://wmsgateway.findmaps. co.uk/wms/IntertecMetocCharts? (internally held
Web Map Service connection);
▪ Royal Yachting Association (RYA) Data for 2020;
▪ Marine Mammal Observation (MMO) fishing data, 2019;
▪ Marine Traffic, www.marinetraffic.com;
▪ Royal National Lifeboat Institution incidents 2008 to 2022. https://data-
rnli.opendata.arcgis.com/datasets/rnli-returns-of-service?geometry=-
46.917%2C50.370%2C36.711%2C59.196;
▪ Marine Accident Investigation Branch (MAIB) annual reports 2017 to 2021.
https://www.gov.uk/governmentcollections/maib-annual-reports.
Additional review of the following reports has also informed this NRA:
▪ AECOM Pentland Firth East Submarine Cable Replacement: Navigational Risk Assessment Report
Kirkwall (60591722-REP-03), 2019;
▪ Cathie Pentland Firth East (2) Cable Replacement CBRA (C1172R01, issue 03), 2020.

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1.1.3 Summary of Stakeholder Consultation

The project has been discussed in general terms at recent meetings with the following navigation
related stakeholders:
▪ Orkney Harbours (Orkney Islands Council);
▪ MCA;
▪ Scottish Fishermen’s Federation;
▪ Orkney Fishermen’s Association; and
▪ Northern Lighthouse Board.
On 19th February 2019, there was a Navigation Risk Assessment workshop facilitated by AECOM as
part of the AECOM NRA report (2019) where 23 hazards were identified and discussed. This was
attended by Orkney Fisheries, Orkney Council, Orkney Ferries, Northlink Ferries and SSE.
There have been no specific mitigation measures discussed, although the licence application for the
new route will be the same corridor as the previously installed cable.

1.1.4 Study Area

This section covers the marine components of the cable installation works through the Pentland Firth
Strait. The study area has been defined as 10 km either side of the proposed Application Corridor.
Kilometre points (KPs) have been assigned to the route using the Rackwick Bay landfall on Hoy as KP0,
up to the Murkle Bay landfall on Scottish mainland as KP35 and are shown in Figure 1-1 (Ref: P2577-
LOC-004).
All AIS data and navigational features dataset presented in this report are limited to the area of the
assessment, hereby known as the Study Area.

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 PENTLAND FIRTH EAST (3)
450000 475000 500000

CABLE REPLACEMENT
LOCATION OVERVIEW
Cable Route Corridor

Drawing No: P2577-LOC-004 A

Legend

KP 0
KP
Installation Corridor
.
6525000

6525000
KP 5

KP 10

KP 15

KP 20

KP 25

KP 30
6500000

6500000
NOTE: Not to be used for Navigation
Date 18 November 2022
KP 35
Coordinate System WGS 1984 UTM Zone 30N
Projection Transverse Mercator
Datum WGS 1984

Data Source MarineFind; ESRI; SSE

J:\P2577\MXD_QGZ\01_LOC\
File Reference
P2577-LOC-004.mxd
Created By Alice Gymer
Reviewed By Irinios Yiannoukos
Approved By Andrew Page

km © Metoc Ltd, 2022

450000 475000 500000 0 3 6 9 12 All rights reserved.

Contains Ordnance Survey data © Crown copyright and database right 2013; Charts from MarineFIND.co.uk © British Crown and OceanWise, 2020. All rights reserved. License No. EK001-FN1001-03265 Not to be used for Navigation
Scottish Hydro Electric Power Distribution plc.
Pentland Firth
Navigational Risk Assessment

1.2 Guidance Methodology

The Navigation Risk Assessment (NRA) methodology used in this section differs slightly from a
significance assessment and has been prepared in accordance with the guidance below:
▪ International Maritime Organisation (IMO) Guidelines for Formal Safety Assessment (FSA) –
MSC-MEPC.2/Circ.12/Rev.2
Whilst not necessarily directly applicable to marine cable projects, consideration to linear cables in
relation to offshore renewable structures has been considered using:
▪ Maritime and Coastguard Agency (MCA) MGN 543 (Merchant and Fishing) Safety of Navigation
Offshore Renewable Energy Installations (OREIs) – Guidance on United Kingdom (UK)
Navigational Practice, Safety and Emergency Response (MCA 2016) and industry best-practice;
▪ Marine Guidance Note “Offshore Renewable Energy Installations (OREIs) - Guidance to
Mariners operating in the vicinity of UK OREIs”; and
▪ Methodology for Assessing the Marine Navigational Safety Risks & Emergency Response of
Offshore Renewable Energy Installations.
Where applicable, further consideration has been given to:
▪ Port Marine Safety Code (PMSC) (Dept. for Transport & Maritime and Coastguard Agency Nov
2016); and
▪ Guide to Good Practice on Port Marine Operations (GtGP) (Dept. for Transport & Maritime and
Coastguard Agency Feb 2018).
The assessment has been informed by the above guidance which states that the assessment stage
should follow a clear progression; from the characterisation of the hazard, the risk that hazard has on
(in the case of this assessment) the existing shipping baseline and the steps & risk controls that are in
place to reduce the overall impact of the hazard to As Low As Reasonably Practicable (ALARP).
The assessment process involves the following main steps presented in Figure 1-2.

Figure 1-2 Assessment Steps

Data gathering on baseline environment

Identification of the Hazard

Risk Analysis

Risk Assessment

Establish Mitigation

Risk Control

For the purposes of this document the definition of “Hazard”, “Risk” and “Maximum Displacement”
are detailed below.
▪ Hazard - A potential source of marine incidences & collisions to the existing baseline of other
marine users.
▪ Risk - The probability of suffering harm, loss or displacement and is a measure of the probability
and consequence of a hazard.

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▪ Maximum Displacement – defined as the maximum number of vessels affected and duration
of displacement during the installation operations, as a result of the installation operations.
The steps presented in Figure 1-2 are described in more detail below.

1.2.2 Data gathering on baseline environment

To assess the potential effects resulting from the operation, it is necessary to establish the current
shipping conditions and features that exist along and near the Proposed Development. A 10 km buffer
has been applied around the Project to ensure that all shipping patterns and navigational features are
captured.
The analysis has included:
▪ Potential accidents resulting from navigation activities – Marine Accident Investigation Branch
(MIAB) & Royal Lifeboat National Institution (RLNI);
▪ Navigation activities affected by the Proposed Development;
▪ Project structures that could affect navigation activities, such as external protection installed
on the seabed;
▪ Project phases that could affect navigation activities;
▪ Other structures and features that could affect navigation activities;
▪ Vessel types involved in navigation activities;
▪ Conditions affecting navigation activities;
▪ Human actions related to navigation activities for use in hazard identification (if possible).

1.2.3 EMODnet dataset grouping

The EMODnet vessel density maps have been created from Automatic Identification System (AIS) data,
collected by coastal stations and satellites. They provide the total ship presence time for 14 individual
ship categories (as given in Table 1-1) for every month of 2021 on a 1 km grid that follows the EEA /
Inspire standards.

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Table 1-1 EMODnet Ship Category Descriptions

EMODnet Ship Category AIS Ship Type Description

Other Wing in ground (WIG), Other, Spare, Diving Ops, Reserved

Fishing Fishing
Pilot vessel, Search and Rescue vessel, Port Tender, Anti-pollution
Service
equipment, Medical Transport
Dredging or underwater operations Dredging or underwater ops
Sailing Sailing
Pleasure craft Pleasure craft Category A to B
High-speed craft High-speed craft
Tug and towing Towing, Tug
Passenger Passenger Category A to B
Cargo Cargo Category A to B
Tanker Tanker Category A to B
Military and law enforcement Military ops, Law Enforcement
Unknown Unknown
Source: EMODnet (2021)

The ship category ‘unknown’ does not have relevant details in the raw AIS data and, therefore, cannot
be assigned to a relevant category.

1.2.4 RNLI dataset grouping

RNLI incident callout data documents marine incidents between 2008 and 2020. For this assessment,
the assigned classifications have been further grouped so the data can be visualised and assessed
clearly. Table 1-2 details the applied grouping.

Table 1-2 Applied Grouping of RNLI Data

RNLI Data Classification Intertek Grouping for Assessment

Vessel abandoned derelict or adrift

Abandoned Vessel
Vessel abandoned, derelict or adrift
Capsize Capsize
Collision
Collision with object on surface
Collision with other craft
Collision with rocks Collision
Collision with submerged object
Criminal activity
Hit by craft
Equipment failure Equipment failure
Fire
Fire on board vessel
Fire / Explosion
Fouled propeller / impeller Fouled Propeller

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RNLI Data Classification Intertek Grouping for Assessment

Leaks / Swamping Leak & Swamping
Machinery failure Machinery failure
Man overboard Man overboard
Adverse conditions
Blown / Swept out to sea
Currents
Cut off by tide
Flooding
High winds
In danger of being carried away by tide
In danger of drowning
MetOcean Conditions
Overcome by crashing waves
Rip current
Stranded
Stranding / Grounding
Stranding or grounding
Stuck in mud
Sudden wave
Swamping
Aircraft crashed
Aircraft thought to be in trouble
Ambulance or doctor call
Animal in trouble
Attempting recovery of item
Attempting rescue of a casualty
Attempting rescue of an animal
Attempting to evade police
Cause (other)
Marine Debris or Object
Other
Medical condition
Missing or overdue
Motor vehicle in the sea
No service
Open channel VHF
Other
Risk taking behaviour
Safety Cover
Signal blocking VHF channel
Slippery or uneven surface

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RNLI Data Classification Intertek Grouping for Assessment

Sporting injury
Stepped to edge e.g. to take photo or look at the scene
Thought to be in trouble
Trapped in motor vehicle
Unexploded bomb / mine
Unknown
Unsure of position (lost)
Cliff collapsed
Dementia senility or other similar condition
Disability
Exhaustion / fatigue / cold
Fear of drowning
Fell from height on craft (e.g. rigging or mast)
Footing gave way
Human error
Ill crewman on vessel
Illness Personal Incident
Injured
Person ill
Person in distress
Person Injured
Person missing
Person on shoreline in difficulty
Person recovery
Person to be taken ashore
Person to be taken ashore from a vessel
Fishing gear snagged on underwater obstruction Snagging
Steering failure Steering Failure
Cargo shifted
Gas leak
Out of fuel
Sail failure / dismasting Vessel Distress
Vessel overdue
Vessel thought to be in trouble
Vessel unsure of position
Vessel dragging anchor Vessel Dragging Anchor
Sinking / Sunk Vessel Sinking or Sunk
Darkness or poor visibility Visibility

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1.2.5 Identification of the hazard

The hazard identification phase seeks to build on the work of the data gathering and identify known
hazards expected to be encountered as a result of the marine operations and presence of project
vessels.
The hazards have been identified in relation to where the Project may make it more likely that existing
vessels will deviate from the Collision Regulations (COLREGs), either as an intended or unintended
action.
This may include any effects which the Project might have on existing vessels such as vessels giving
appropriate clearance to cable operations when undertaking cable installation and obstruction to the
light and sound signals made by vessels and navigational aids in particular circumstances.
The approach used for hazard identification comprises a combination of both creative and analytical
techniques, the aim being to identify all relevant hazards. Where relevant, consultation has been
undertaken with stakeholders to help to identify hazards. The creative element is to ensure that the
process is proactive and not confined only to hazards that have materialized in the past.

1.2.6 Risk analysis

The risk analysis introduces the concept of risk in a qualitative way in order to prioritise the hazards
identified during the hazard identification process and assesses their impact on navigational safety.
Risk is the combination of frequency and consequence which are defined in Table 1-3 and Table 1-4.
The definitions below have been developed using the IMO guidelines which includes effects on human
safety and ships, however, this assessment also focuses on displacement of existing vessels and this is
the most likely consequence of the proposed development.

Table 1-3 Frequency of a hazard

Value Description Definition

1 Extremely Remote Likely to occur once in the lifetime of the project (25 years)

2 Remote Likely to occur once per year

3 Probable Likely to occur once per month

4 Very Probable Likely to occur once per week

5 Frequent Likely to occur once per day

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Table 1-4 Consequence of a hazard

Definition
Value Description
Effects on Human Safety Effect on Ship(s) Displacement of Vessel(s)

Single local Temporal displacement of

1 Minor Single or minor injuries
equipment damage vessel (hours)

Multiple local Temporal displacement of

2 Significant Multiple minor injuries
equipment damage vessel (days)

Multiple or severe Non-severe ship and Temporal displacement of

3 Severe
injuries equipment damage vessel (weeks)

Single fatality or multiple Severe damage to Temporal displacement of

4 Serious
severe injuries ship and equipment vessel (months)

Total loss of ship and Permanent displacement of

5 Catastrophic Multiple fatalities
equipment vessels

Risk prioritisation is an important part of the process, the greater the potential of a hazard, the greater
the need to ensure that there are mitigation measures in place to control the risk.

1.2.7 Risk assessment

IMO Guidelines above define a hazard as “something with the potential to cause harm, loss or injury”
the realisation of which results in potential accidents and, in this case, vessel displacement. The
potential for a hazard to be realised can be combined with an estimated (or known) consequence of
outcome. This combination is termed “risk”. Risk is therefore a measure of the frequency and
consequence of a hazard. One way to compare risk levels is to use a matrix approach.
Having established the frequency and consequence of the hazard, a risk assessment has been carried
out using a risk matrix, adapted from the guidance above, presented in Table 1-5.

Table 1-5 Risk Matrix

Consequence

Minor Significant Severe Serious Catastrophic

Extremely
1 2 3 4 5
Remote

Remote 2 4 6 8 10
Frequency

Probably 3 6 9 12 15

Very
4 8 12 16 20
Probable

Frequent 5 10 15 20 25

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At the low end of the scale, frequency is extremely remote and consequence minor; risk can be said
to be negligible. At the high end, where hazards are defined as frequent and the consequence
catastrophic, then risk is intolerable.
The result of using this matrix approach is to ensure that the level of risk is reduced to ALARP for the
effects that the Project has on the baseline shipping environment. This is undertaken prior to any
mitigation. Best Practice and Project Specific Mitigation will then be applied to generally reduces the
effects to ALARP.
Definitions of the risk levels are provided in Table 1-6 below.

Table 1-6 Definitions of risk levels with respect to vessel displacement

Score Classification Definition

A hazard which causes noticeable changes in the navigation environment but

1-2 Negligible
without effecting its sensitivities. Generally considered as insignificant.
A hazard that alters the character of the navigation environment in a manner that
is consistent with existing baseline. Hazards are generally considered as minor and
3-4 Minor adequately controlled by best practice and legal controls. Opportunities to reduce
hazards further through mitigation may be limited and are unlikely to be cost
effective.
A hazard which, by its frequency and consequence alters the aspect of the
navigation environment. Generally considered as Moderate but effects are those,
5-9 Moderate considered to be tolerable. However, it is expected that the hazard has been
subject to feasible and cost-effective mitigation and has been reduced to As Low
As Reasonably Practicable (ALARP) and that no further measures are feasible.
An effect which, by its frequency and consequence alters most of the aspects of
10-14 Major the navigation environment. Generally regarded as unacceptable prior to any
mitigation measures being considered.

15-25 Intolerable Regarded as unacceptable prior to any mitigation measures being considered.

1.2.8 Establish mitigation

The risk assessment includes a review of existing hazards and their associated mitigation measures.
As a result, new mitigation measures (or changes to existing mitigation measures) may be identified
for consideration, both where there are gaps in existing procedures and where mitigation need to be
enhanced.
Care should be taken to ensure that any new hazards created as a result are themselves identified and
managed. The overall risk to the existing baseline during this stage will allow recommendations to be
made to enhance safety.
Mitigation measures are the actions or systems proposed to manage or reduce the potential negative
effects identified. Mitigation measures are sometimes confused with measures taken to ensure legal
compliance, which can be similar. Legislation is often designed to ensure effects to the environment
are minimised.
A standard hierarchical approach to identifying mitigation requirements has been used to inform the
NRA:
▪ Avoid or Prevent: In the first instance, mitigation should seek to avoid or prevent the adverse
effect at source, for example, by routing the marine cables away from a hazard.
▪ Reduce: If the effect is unavoidable, mitigation measures should be implemented which seek to
reduce the significance of the hazard.

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▪ Offset: If the hazard can neither be avoided nor reduced, mitigation should seek to offset the
hazard through the implementation of compensatory mitigation.
Mitigation measures fall into two categories: mitigation which forms part of the Project design which
are referred to as Best Practice (BP) Mitigation; and mitigation which is part of the construction of the
Proposed Development, which is referred to as Project Specific Mitigation.

1.2.9 Risk control

The aim of assessing the Project operations on the existing shipping baseline is to reduce risk As Low
As Reasonably Practicable (ALARP).
The risk assessment is repeated taking into consideration the application of Best Practice and Project
Specific Mitigation. This determines the risk level of the hazard with mitigation applied. When the
risk assessment is carried out after mitigation is applied, the resulting risk level is referred to as ALARP.
Risks that have been assessed as Major or above after considering mitigation will normally require
additional analysis and consultation to discuss and possibly further mitigate hazards where possible.
Where further mitigation is not possible a residual hazard may remain.

1.3 Marine Campaign Works

The Project Description is provided in Appendix A of the Environmental Supporting Information and
provides details of the proposed route and operational aspects of the marine campaign works such as
cable installation, site preparation and cable protection methods. A schedule is also included
estimating the timeframe for the various marine activities.
The operation will be performed on a 24-hour basis. Durations presented are exclusive of weather
downtime above vessel working limits and any third-party influences that may increase the duration
or interrupt operations.
Existing vessels will be requested to remain at least 500 m from project vessels whilst they are engaged
in cable installation activities, resulting in a width of 1 km. This is due to the cable lay vessel’s limited
ability to manoeuvre whilst undertaking operations.
Unless otherwise directed by Notice to Mariners (NtMs), the entire cable route corridor will require to
be kept clear of all fishing gear (mobile and static) until the end of the works, including the post lay
survey period.
Pertinent Information from the project description that is directly relevant to the marine activities for
the NRA is outlined below.

Pre-Lay Survey
A detailed geophysical pre-lay survey will be undertaken across the entire cable route. Typically,
vessels survey at approximately 800 m/hr and is estimated to take approximately 9.1 days (assuming
5 survey lines and excluding weather).
Therefore, as a worst case the maximum area for disruption would be 1 km wide by 19.2 km long
per 24-hour period.

Pre-Lay Grapnel Run (PLGR)

It is anticipated for the PLGR to take up to 6 days. This usually clears the route of any debris such as
OOS cables and fishing gear etc.
Therefore, as a worst case the maximum area for disruption during a PLGR would be 1 km wide by
6.0 km long per 24-hour period.

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Boulder clearance
Large boulders that cannot be avoided during the route engineering process will need to be cleared
on a case-by-case basis. The progress rate for this operation is currently unknown as it depends on the
extent of boulders found that require clearance, but boulder removal is estimated to take up to 4 days.
Boulder removal would be undertaken by a hydraulic operated ‘Orange Peel’ grab.
Therefore, as a worst case the maximum area for disruption during boulder clearance would be 1
km wide by 9.0 km long per 24-hour period.

Cable Shore End Pull-In Operations

The first cable pull in operations are expected to take approximately 1 day to complete and the Cable
Lay Vessel (CLV) will be stationed around the 13 m water depth contour.
Once the cable is laid across the seabed, the cable lay vessel will remain on station at the 13 m water
depth contour at the other shore end. The cable will then float off the vessel to shore to complete the
second cable pull in operation taking another 1 day.

Cable Lay Operations

Once the cable is successfully pulled (first cable pull-in) to its required position onshore, the buoyancy
units will be removed and the CLV will commence laying operations until the second cable pull in. The
CLV is a DP2 (Dynamic Positioning) class vessel and the expected cable laying speed will be between
200 m/hr and 450 m/hr, therefore it is expected to take 11 days to complete cable lay operations.
Therefore, as a worst case the maximum area for disruption would be 1 km wide by 4.8 km long per
24-hour period.

Post-Lay Trenching
Once the cable has been laid on the seabed the cable is then buried using a trenching tool. Typical
burial speeds are expected to be approximately 200 m/h and is estimated to take 12 days.
Therefore, as a worst case the maximum area for disruption would be 1 km wide by 4.8 km long per
24-hour period.

Articulated Pipe Installation

The cable protection strategy may include the installation of Articulated Pipe in very shallow water.
Generally, this is installed following the cable pull-in operations by divers or from the CLV, or by a
combination of both methods where areas require articulating piping. Typical speeds for installing
articulated piping are expected to be approximately 0.6 m/hr, and durations are estimated at 15.0
days for Murkle Bay and 7.5 days for Rackwick Bay.

Rock bags for cable stabilisation

Rock bags are anticipated to be used as a means of stabilising the cable where deemed necessary by
the On Bottom Stability Analysis. It is expected that the quantity of rock bags will be similar to the
previously installed figure (378) and the estimated duration would be 28 days.

Mattress Installation
Two fibre optic cable crossings will be required along the proposed route. In order to cross the fibre
optic cable, concrete mattresses are proposed to protect both the existing cable and the proposed
cable. There are likely to be three pre lay concrete mattresses (6 m long, 3 m wide) and one post lay
mattress per crossing.
The existing crossing points will most likely be re-utilised but there is still potential for new ones to be
required.
Typical mattress installation speeds are around 1 mattress every 4 hrs and, with eight mattresses
anticipated in total, would consequently take approximately 16 hrs per crossing.

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Navigational Risk Assessment

Decommissioning of Out of Service cable

The Out of Service Pentland Firth East (2) cable will be removed to facilitate the installation of Pentland
Firth East (3) according to the decommissioning plan (Appendix F of Environmental Supporting
Information). Clump weights will be installed to secure any cut cable ends.
Similar vessels as used in installation will be involved but the expected rate for decommissioning the
will be similar to that of the cable laying operations. There may be some de-burial operations to
excavate the cable in areas of deep cable burial which will have similar rates to post lay trenching
operations.

Operational Phase
Routine inspections to examine the subsea infrastructure would take place periodically every 5-8 years
after installation during the lifetime of the cable. This would involve a 500 m radius around the survey
vessel moving at 150 m/hr.
Therefore, as a worst case the maximum area for disruption would be 1 km wide by 3.6 km long per
24-hour period.

1.4 Existing Baseline Assessment

1.4.1 Shipping Overview
12 months of AIS data from Jan to December 2021 were analysed within 10 km of the cable corridor
to examine the types and patterns of shipping activity occurring near the Application Corridor. The
total average monthly vessel density can be observed in Figure 1-5 (P2577-AIS-001).
A total vessel density of over 31,000 vessel hours were recorded across the Study Area in 2021. The
distribution of the vessel categories are presented in Figure 1-3. It can be seen that many cargo (25.6%)
and fishing (22.1%) vessels make up the AIS dataset, whilst passenger vessels constitute 15.6% and
dredging/underwater operations make up 14.5%.
In 2021, dredging vessels were present near Scrabster Harbour to facilitate the St. Ola Pier
refurbishment. This resulted in moderate AIS intensity (26 vessel hours per km2) 200 m to the South-
West of KP30, but this operation was completed December 2021.

14 P2577_R5880_Rev2 | 21 November 2022

Scottish Hydro Electric Power Distribution plc.
Pentland Firth
Navigational Risk Assessment

Figure 1-3 Vessel Distribution Across the Pentland Firth East Route

Figure 1-4 highlights the seasonal changes in vessel distribution.

Dredging/underwater operations are very seasonally dependent with higher proportions of vessels
between March (18.4%) and August (30.2%) compared to November (0.5%) to January (0.1%).
In addition, the percentage of fishing vessels halves in summer months (May – September) at 14.4% -
16.6% in comparison to the rest of the year (October – April) ranging from 22.1% - 34.8%. It is
important to note that less fishing vessels will be present during installation operations as these
activities generally take place in more favourable weather windows (summer months).
There was a spike in January 2021 where Tug and Towing vessels made up 17.6% of the vessel density,
which is a significant increase from low levels throughout the other months (average was 3.6%).
Furthermore, cargo vessels were consistently present in relatively high proportions throughout 2021,
ranging from 19.0% in August and 31.5% in January, with an average of 25.6%.

15 P2577_R5880_Rev2 | 21 November 2022

Scottish Hydro Electric Power Distribution plc.
Pentland Firth
Navigational Risk Assessment

Figure 1-4 Seasonality Changes in Vessel Traffic Across the Pentland Firth East Route

The vessel density across the Study Area is generally relatively low with a mean of 1.2 vessel hours per
km2.
The cable corridor itself is within slightly higher vessel densities which tend to range from 2-5 vessel
hours per km2 with a maximum of 8 near KP21 where a horizontal pattern of traffic can be seen across
the Pentland Firth. This pattern can be attributed to cargo vessels which tend to travel between KP18
and KP23, perpendicular to the cable corridor. Tanker vessels additionally travel along the same route
at lower densities between KP20 and KP23.
A near vertical pattern of moderate vessel density (~3 vessel hours per km2) can be seen stretching up
from Thurso past the West coast of the Isle of Hoy. This pattern is due to the regular passenger ferry
line between Thurso and Stromness, which travels 2-3 times each day. The cable corridor mostly
follows this pattern for 9.8 km from KP20 to KP28 and crosses the corridor for 2.3 km from KP5 to KP8.
Low vessel densities are present directly near the two landfall sites – Rackwick Bay has an average of
0.3 vessel hours per km2 and Murkle Bay ranges from 0.05 to 3.4 vessel hours per km2. However, the
highest vessel traffic can be observed at Scrabster (West of Murkle Bay and 22.5 km SW of KP 30),
where vessel density reaches 280 vessel hours per km2, due to Scrabster Harbour (facilitating cargo,
tanker, dredging, tug/towing, service vessels and pleasure craft) and the ferry terminal.
The latest Marine Traffic data from 2021 has been investigated and the average of all vessels are
displayed in Figure 1-6. The Study Area is shown in a black outline and cable corridor displayed in red.
At the Rackwick Bay landfall, there is a slightly higher intensity area within the bay, which can be
attributed to High Speed Craft (0.4 vessel hours per km2).

16 P2577_R5880_Rev2 | 21 November 2022

 PENTLAND FIRTH EAST (3)
475000 500000

CABLE REPLACEMENT
AIS VESSEL DENSITY
Average Monthly Vessel Density - All Vessels

Drawing No: P2577-AIS-001 A

Legend
KP
Installation Corridor
10 km Buffer
All Vessels - Average
Vessel hours per km²
.
0
< 0.05
0.05 - 0.1
KP 0 0.1 - 0.2
0.2 - 0.5
6525000

6525000
0.5 - 1
KP 5 1-2
2-5
5 - 10
10 - 20
KP 10
20 - 50
50 - 100
100 - 200
200 - 500
> 500
KP 15

KP 20

NOTE: Not to be used for Navigation

KP 25 Date 22 September 2022
Coordinate System WGS 1984 UTM Zone 30N
Projection Transverse Mercator
Datum WGS 1984

Data Source
KP 30 OSOD; EMODnet; SSE
6500000

6500000
J:\P2577\MXD_QGZ\02_AIS\
File Reference
P2577-AIS-001.mxd
Created By Alice Gymer
Reviewed By Irinios Yiannoukos
KP 35
Approved By Andrew Page

km © Metoc Ltd, 2022

475000 500000 0 2.5 5 7.5 10 All rights reserved.

Contains Ordnance Survey data © Crown copyright and database right 2013; British Crown and OceanWise, 2020. All rights reserved. License No. EK001-FN1001-03265 Not to be used for Navigation Information contained here has been derived from data that is made available under the European Marine Observation Data Network (EMODnet) Human Activites project (https://www.emodnet-
humanactivities.eu/about.php), financed by the European Union under Regulation (EU) No 508/2014 of the European Parliament and of the Council of 15 May 2014 on the European Maritime and Fisheries Fund.
Scottish Hydro Electric Power Distribution plc.
Pentland Firth
Navigational Risk Assessment

Figure 1-6 Vessel Activity in the Pentland Firth

Marine Traffic

The average number of vessels transiting the Pentland Firth each day remains fairly consistent across
the year, with offshore and passenger vessels seeing increases of five and ten vessels per day during
the summer respectively. Passenger vessels account for a high number of average vessels per day,
with the Pentland Firth being used regularly by Serco NorthLink's ferry which operates between
Scrabster and Stromness, and Pentland Ferries’ ferry which operates between Gills Bay and St.
Margaret’s Hope. The cable corridor is located approximately 19 km from the Gills Bay – St Margaret’s
Hope route, therefore project vessels are too far a way to interfere. The cable corridor intersects the
Scrabster - Stromness ferry route at three points, for approximately 0.7 km between KP8.9 and KP 9.5,
approximately 2.9 km between KP22.9 and KP25.8, and perpendicularly crosses the cable at KP30 for
500 m.

1.4.2 Navigational Features and Anchorages

There is an International Marine Organisation Area to be Avoided traffic routing scheme around the
West, North and East of the Orkney Islands, where vessels of more than 5,000 gross tonnage that carry
oil or other hazardous material should avoid. This covers the West of Hoy and Stromness, intersecting
with the cable corridor from KP0 to approximately KP8, however it will not interfere with the vessels
used during this operation. Admiralty chart notes advise that laden tankers not bound to or from Flotta
and Scapa Flow should not use the Pentland Firth in restricted visibility or adverse weather (AECOM
NRA, 2019).

On the Scottish mainland north coast, there are four ports: two larger ports at Scrabster and Thurso;
a small private port at Castlehill (near Castletown) and a small municipal port at Dwarwick (near
Dunnet), where recreational diving takes place. A private slipway is also present in Brough Bay (East
of the Easter headland). The Pentland Firth cables fall within the Scrabster Harbour Authority

18 P2577_R5880_Rev2 | 21 November 2022

Scottish Hydro Electric Power Distribution plc.
Pentland Firth
Navigational Risk Assessment

boundary, which stretches from Scrabster to Castletown. In addition, berthing and overnighting of
survey vessels may occur within harbour limits.

There are no navigational buoys within the study area.

1.4.3 Royal Yachting Association (RYA)

RYA clubs, training centres, marinas as well as the RYA AIS data within the Study Area are illustrated
in Figure 1-7 (P2577-RYA-001-A). The figure also presents a heat map of AIS data of the recreation
boating activity across study area.

RYA AIS intensity data is limited in the study area, resulting in significant patches of no data especially
between KP5 and KP20, however the available data indicates low to negligible AIS intensity (0.3 - 0.8)
throughout the study area. However, there is moderate AIS intensity (1.8) in close vicinity of Scrabster
Harbour.

The Pentland Firth Yacht Club (blue triangle) and one training centre (red triangle) are located in
Scrabster Harbour 7 km to the West of the Murkle Bay landfall and the closest distance from the cable
corridor is 5 km South-West of KP30. Sailing from RYA tends to occur within Thurso Bay itself, resulting
in moderate AIS intensity (1.8) in close vicinity of Scrabster Harbour. Recreational activity is therefore
unlikely to be affected during the cable operation.

There are no general boating areas within the study area.

The North Caithness Coast and Orkney waters are used by small numbers of sailing vessels each year,
with the summer months seeing significantly higher numbers than in the winter. Vessels typically visit
the main ports and marinas of the region including Westray, Kirkwall, Stromness and Scrabster.

19 P2577_R5880_Rev2 | 21 November 2022

 PENTLAND FIRTH EAST (3)
450000 475000 500000

CABLE REPLACEMENT
Kirkwall ROYAL YACHTING ASSOCIATION
Marina RYA UK Coastal Atlas of Recreational Boating
Stromness
Orkney Drawing No: P2577-RYA-001 A
Marina
Harbours
Legend
KP

¢
RYA Club
RYA Training Centre
¢

[
h Marina
Installation Corridor
10 km Buffer
General Boating Area
AIS Intensity (Recreational Yachting)
KP 0
Intensity
6525000

6525000
Low

KP 5

KP 10

High

KP 15

KP 20

KP 25
NOTE: Not to be used for Navigation
Date 22 September 2022
Coordinate System WGS 1984 UTM Zone 30N
KP 30 Projection Transverse Mercator
6500000

6500000
Datum WGS 1984

Scrabster Data Source OSOD; RYA; SSE

Harbour
KP 35
J:\P2577\MXD_QGZ\05_RYA\
File Reference
P2577-RYA-001.mxd
Created By Alice Gymer
Reviewed By Irinios Yiannoukos
Approved By Andrew Page

km © Metoc Ltd, 2022

450000 475000 500000 0 3 6 9 12 All rights reserved.

Contains Ordnance Survey data © Crown copyright and database right 2013; British Crown and OceanWise, 2020. All rights reserved. License No. EK001-FN1001-03265 Not to be used for Navigation © Data reproduced under licence from the Royal Yachting Association
Scottish Hydro Electric Power Distribution plc.
Pentland Firth
Navigational Risk Assessment

1.4.4 Fishing Overview

The Commercial Fishing section provides a detailed assessment of the effects that the
installation/operation of the replacement cable and decommissioning of the nearshore ends of the
existing cable could have on fishing within the Study Area.
Many different fishing gears and fishing methods are used by commercial fisheries. Each gear type is
used for specific activities and different gears can have very different impacts on the marine
environment and cable security. Furthermore, it is possible for smaller fishing vessels to bottom out
if they become snagged on subsea cables.
This section has used information provided in the Fishing Liaison Mitigation Action Plan (FLMAP), the
PFE (2) CBRA (2020) and Vessel Monitoring System (VMS)/vessel traffic data to identify the main areas
of fishing in relation to the Project which may be disrupted during the offshore marine campaigns.
Fishing from VMS data appears to be fairly consistent across the route with a vertical pattern to the
West of Hoy, adjacent to Melvich where fishing activity is relatively more intense. There are
additionally areas of no data to the South of Hoy, as shown in Figure 1-8 (Ref: P2557-FISH-001).
Within the Pentland Firth and Orkney Waters, creeling is the most popular method of fishing. Within
ICES rectangle 46E6, creeling accounts for three-quarters of fishing effort, with the top species
targeted being crab, lobster and haddock (see Section 7 of the FLMAP). Bottom (demersal) trawling,
such as otter trawling, and scallop dredging, are also common fishing activities within the Pentland
Firth, but low levels occur within the Study Area itself. Demersal gear types pose a significant risk to
the cable as they are towed along the seafloor and can snag and damage subsea cables. The depth of
penetration indicates the risk to the cable from fishing gear, however, fishermen do reduce
penetration where possible to decrease risk of losing equipment and consume less fuel. Depending on
the substrate, scallop dredging can result in a penetration up to 35 cm deep.
The size (6 m to 19 m) of static gear vessels vary, however smaller fishing vessels may not be recorded
by AIS/VMS. Creeling conducted by vessels under the length of 10 m, working nearshore between the
Orkney islands will most likely be the primary source of conflict during any cable works as creeling
activity by this size of vessel is typically confined to the nearshore area.
Static gear fishing vessels mainly use the port of Stromness for operations. Demersal trawling is more
prevalent in close proximity to Rackwick Bay. Mobile/active fishing gear is seasonally restricted along
the West coast of Hoy (The Berry to Costa Head). Scallop dredging is prohibited from the headland
North of Scrabster Harbour to Dunnet Head (including Thurso Bay, Murkle Bay and Dunnet Bay) 1.
Fishing effort in the region follows a seasonal pattern with activity varying to shelter from adverse
weather conditions, reacting to seasonal changes and exploiting target species 2.

1
Marine Scotland (2022). National Marine Plan Interactive (NMPi). Accessible here:
https://marinescotland.atkinsgeospatial.com/nmpi/default.aspx?layers=311 [accessed November
2022]
2
Coleman M T., & Rodrigues E. (2016). Orkney Shellfish Project End of Year Report: January –
December 2015. Orkney Sustainable Fisheries Ltd. No.13, pp. 86

21 P2577_R5880_Rev2 | 21 November 2022

 450000 500000 450000 500000 450000 500000

Demers
alGear T
otalWei
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Tonnes
) Demers
alGear T
otalValue(
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47E6 47E7 47E6 47E7 47E6 47E7

47E5 47E5 47E5
6550000

6550000
46E5 46E7 46E5 46E7 46E5 46E7
46E6 46E6 46E6
6500000

6500000
45E5 45E6 45E7 45E5 45E6 45E7 45E5 45E6 45E7

450000 500000 450000 500000 450000 500000

PE
NTL
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EEZ Boundary T
otalWei
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Installation Corridor (Tonnes) (£ Sterling) (kilowatt/hours) Da
tum WGS 1984
ICES Rectangle > 0 - 10 (Tonnes) > £0 - £10,000 > 0 - 2,500 (kilowatt/hours) Da
taS
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> 10 - 20 > £10,000 - £20,000 > 2,500 - 5,000 J:\P2577\MXD_QGZ\04_FISH\
F
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tedBy Alice Gymer
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> 80 - 160 > £80,000 - £160,000 > 20,000 - 40,000
Approv
edBy Andrew Page
> 160 - 320 > £160,000 - £320,000 > 40,000 - 80,000
> 320 - 640 > £320,000 - £640,000 > 80,000 - 160,000
> 640 - 1,280 > £640,000 - £1.28 million > 160,000 - 320,000
> 1,280 - 2,560 > £1.28 - £2.56 million > 320,000 - 640,000
© MetocL td,2022
> 2,560 (Tonnes) > £2.56 million > 640,000 (kilowatt/hours)
NOT
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Flanders Marine Institute (2019). Maritime Boundaries Geodatabase: Exclusive Economic Zone (EEZ), version 11. Available online at http://www.marineregions.org/. https://doi.org/10.14284/386; Contains public sector information, licensed under the Open Government Licence v2.0, from the UKHO, 2018.; Open Government Licence reproduced with permission of the Marine Management Organisation.; Contains
Ordnance Survey data © Crown copyright and database right 2013; ©ICES; ©Esri
Scottish Hydro Electric Power Distribution plc.
Pentland Firth
Navigational Risk Assessment

1.4.5 Marine Accident Data

This section reviews maritime incidents that have occurred within 10 km of the cable routes across
the Pentland Firth. The analysis is intended to provide a general indication as to whether the area of
the Project is currently a low or high-risk area in terms of maritime incidents. If it were found that the
proposed development resided in a high-risk area for incidents, this may indicate that the
development could add to the existing maritime safety risks in the area.
The most recently available 12 years of data from RNLI and the last 5 MIAB annual reports have been
analysed. It is noted that the same incident data could have been recorded by both sources.

1.4.5.1 RNLI
The most recent twelve-year period available of RNLI data (collected between 2008 and 2020) has
been plotted spatially and analysed across the study area.
The dataset is a condensed Return of Service data from RNLI callouts across the United Kingdom. It is
worth noting that there are records present that have not been spatially adjusted to their exact
locations but does give an indication of the number of marine incidences in the area.
A total of 76 launches across the study area (all to unique incidents) were recorded by the RNLI
(excluding hoaxes and false alarms) over the last 12 years. This corresponds to an average of around
6 incidents per year indicating that the number of incidents in the Pentland Firth is very low.
Incident type and corresponding years for across the study area are presented in Figure 1-9. RNLI
categories that are not relevant to this assessment have assigned to the category ‘Other’.

Figure 1-9 RNLI Yearly Callouts

With the exception of ‘Other’ (17 incidents), which, as mentioned above is not relevant to this
assessment, it can be seen that for ‘Personal Incidents’ (21 incidents), ‘Machinery Failure (11 incidents)
and ‘MetOcean Conditions’ (8 incidents, e.g. due to strong tidal currents and wave bores that can
overpower vessels) account for a large portion of the dataset. Similarly, there have been a relatively
low number of recorded collisions (4 incidents) over the last 12 years.
The highest proportion of call outs were to commercial vessels (36%) and people (30%). This indicates
that fishing and cargo vessel incidents are more likely within the study area, in addition to a number
of personal incidents especially nearshore Thurso.
As a result of the temporal effects of the offshore marine campaign works, and that incidences are
largely as a result of Personal Incidences (e.g. person in distress, missing person, person in water) and
machinery breakdowns and vessels being caught out in the commonly severe MetOcean conditions
occurring in the Pentland Firth, it is not thought that the presence of project vessels will increase the
risks to the existing baseline of marine safety.
Figure 1-10 (Ref: P2577-RNLI-001) presents the locations of incidences recorded by the RNLI.

23 P2577_R5880_Rev2 | 21 November 2022

Scottish Hydro Electric Power Distribution plc.
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Navigational Risk Assessment

Figure 1-10 Recorded Incidents between 2008 and 2020 (P2577-RNLI-001)

1.4.5.2 MAIB
All UK-flagged commercial vessels are required by law to report accidents to MAIB. Non-UK flagged
vessels do not have to report unless they are within a UK port/harbour or are within UK 12 nautical
miles (NM) and carrying passengers to or from a UK port. However, the MAIB will always record details
of significant accidents of which they are notified by bodies such as the Coastguard. The Maritime and
Coastguard Agency, harbour authorities and inland waterway authorities also have a duty to report
accidents to the MAIB.
The last 5 years of annual MAIB reports from 2017 to 2021 have been analysed to determine if any
accidents have occurred within or nearby the Pentland Firth. The findings have been summarised
below as:
▪ 2021: No incidents or accidents relating to vessels at sea within the vicinity of the study area.
▪ 2020: 31st October - Loss overboard of 33 ISO containers from the container vessel Francisca
(9113214) near Duncansby Head, Scotland (20 km East of the study area).

24 P2577_R5880_Rev2 | 21 November 2022

Scottish Hydro Electric Power Distribution plc.
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Navigational Risk Assessment

▪ 2019: No incidents or accidents relating to vessels at sea within the vicinity of the study area.
▪ 2018: 18th July - Grounding of the Netherlands registered general cargo vessel Priscilla in the
Pentland Firth, Scotland.
▪ 2017: No incidents or accidents relating to vessels at sea within the vicinity of the study area.
A total of two marine incidents were reported across or near the study area, corresponding to an
average of 0.4 incidences a year. One of those incidents in 2020 took place near Ducansby Head, which
is 20 km East of the cable route. It can be seen that in 2021, 2019 and 2017, there were no incidents
or accidents reported by MAIB.
It is worth noting that none of the incidents relate to a collision with other vessels so this area of the
sea can be deemed relatively incident free.
Furthermore, a recent incident also took place in July 2022 within the Pentland Firth by Swona on the
Gills Bay-St Margaret’s Hope ferry line, which is currently under investigation by the MAIB:
▪ 2022 (up to September): 5th July - Grounding of a UK registered ro-ro passenger ferry (MV Alfred)
on Swona Island, Scotland.

25 P2577_R5880_Rev2 | 21 November 2022

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Navigational Risk Assessment

1.5 Hazard Identification

Marine operations and their associated hazards have been identified and listed in Table 1-7. A hazard
has been assigned to each aspect of the marine operation including the zone of influence, resulting in
a worst-case assessment. The zones of influence are also presented in the table below.

Table 1-7 Marine Operations and Identified Hazards – Shipping and Navigation

Project Phase Operation Hazard Identified Receptor Zone of Influence

1km wide x 19.2km

Pre-Lay Survey along centreline (in
any 24-hour period)
1km wide x 6.0km
Pre-Lay Pre-Lay Grapnel Run along centreline (in
any 24-hour period)
1km wide x 9.0km
Boulder Clearance along centreline (in
any 24-hour period)

Shore End 1km wide x 7.2km

Operations (cable ▪ Displacement of vessels along centreline (in
pull in) due to avoidance of any 24-hour period)
project vessels
▪ Vessel Collision 1km wide x 4.8km
Cable Lay Project along centreline (in
▪ Project vessels blocking
vessels; any 24-hour period)
navigational features
Commercial 1km wide x 2km at
Offshore ▪ Fishing interaction with
shipping; crossing and burial
installation, post-lay Surface laid cable
Recreational, locations (in any 24-
trenching ▪ Accidental anchoring on boating and
surface laid cable hour period)
fishing
Installation ▪ Extreme weather vessels
1km wide x 4.8km
Mattress conditions
along centreline (in
Installation ▪ Displacement of vessels any 24-hour period)
due to avoidance of
project vessels
1km wide x 1km along
Articulated Pipe
centreline (in any 24-
Installation
hour period)

1km wide x 1km along

Rock Bag
centreline (in any 24-
Installation
hour period)

1km wide x 3.6km

Operation and
Routine Inspection along centreline (in
maintenance
any 24-hour period)

1.6 Risk Control

1.6.1.1 Compliance Mitigation
The Compliance measures included in Table 1-8 are required to be undertaken to meet environmental
and health and safety legislation.

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Navigational Risk Assessment

Table 1-8 Compliance Mitigation

ID Embedded mitigation

Project vessels will comply with the International Regulations for Preventing Collisions at Sea, 1972
COMP 1
(COLREGs) – as amended, particularly with respect to the display of lights, shapes and signals.
‘As-laid’ co-ordinates of the cable route will be recorded and circulated to the UK Hydrographic Office
(UKHO), KIS-ORCA service and any other relevant authorities. Cables will be marked on Admiralty
COMP 2
Charts and KIS-ORCA charts (paper and electronic format). An update will be distributed to
stakeholders following the completion of installation.
Where weather reduces visibility then vessel masters shall adhere to MGN guidelines and COLREGS to
COMP 3
prevent collisions at sea.

1.6.1.2 Best Practice Mitigation

The Best Practice project mitigation relevant to shipping is provided in Table 1-9. When undertaking
the assessment, it is assumed that these measures will be complied with - either as a matter of best
practice or to ensure compliance with statute.

Table 1-9 Best Practice Mitigation

ID Embedded mitigation

BP1 Early consultation with relevant contacts to notify of impending activity.

Notice to Mariners will be published to inform sea users via Notices to Mariners, Kingfisher Bulletins
BP2 and Maritime and Coastguard Agency (MCA) and UK Hydrographic Office (UKHO). Vessels will be
requested to remain at least 500 m away from cable vessels during installation operations.
A guard vessel may be used during the installation campaign where a potential risk to the asset or
BP3
danger to navigation has been identified.
Appropriate cable protection to be installed as applicable along the cable route including over shallow
BP4
burial areas if required.
An onshore Fishing Liaison Officer (FLO) will be provided for the project. The FLO will follow the
BP5 Fishing Liaison Mitigation Action Plan (FLMAP) and ensure the entire corridor is kept clear of fishing
gear until all operation have been completed.
The UKHO will be informed of installation activities in order to issue Maritime Safety Information (MSI)
BP6
broadcasts as appropriate.
Marine Guidance Notice (MGN) provided by the UKHO, IHO and International Convention for the
Safety of Life at Sea (SOLAS) recommend that fishing vessels should avoid trawling over installed
BP7
seabed infrastructure (MCA, 2021) 3. Vessels are advised in the Mariners Handbook not to anchor or
fish (trawl) within 500 m of the cable
If cables are buoyed off whilst the vessel departs the area, buoy positions will be notified to the Notice
BP8
to Mariners (NTM) distribution list including Kingfisher and 500 m clearance will be requested.
`

3
Marine & Coastguard Agency. (MCA; 2021). MGN 661 (M+F) Navigation – safe and responsible
anchoring and fishing practices. [online]. Available at:
https://www.gov.uk/government/publications/mgn-661-mf-navigation-safe-and-responsible-
anchoring-and-fishing-practices/mgn-661-mf-navigation-safe-and-responsible-anchoring-and-fishing-
practices

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2. RISK ANALYSIS
The descriptions and definitions in the below risk analysis takes into consideration the applied
mitigation needed to reduce the hazards to ALARP, resulting in the residual risk ratings.

2.1 Displacement of vessels due to the avoidance of project vessels

Existing vessels may have to re-route around or reduce speed on approach to the project vessels which
may causing a disturbance in the existing shipping patterns.
The presence of the project vessels will add an additional hazard for mariners to be aware of, which
will potentially make them more vigilant when navigating through the area. In most cases, there is
ample ‘sea room’ for existing shipping to manoeuvre around the project vessels. However, in extreme
cases, existing shipping may need to give way to project vessels temporarily due to the geography of
Inter-Island landmasses and relatively short routes.
Since the project vessels will be moving along at the rate of the PLGR/Cable Installation operations
(speed is dependent on installation method used), any disruption will be temporary and short term in
any one location. As shipping will have to make minor diversions to avoid the project vessels, their
frequency has been assessed as Remote. For slower operations (cable protection installation),
disruption due to the presence of project vessels would be Probable.
The consequence has been assessed as Minor because it will be very short-term, temporary, and
acceptable alternatives for route planning are available for shipping traffic to easily manoeuvre around
project vessels.

2.2 Collision Risk

Existing vessels may have to re-route around project vessels which may create pinch points and alter
the rate of encounters. Therefore, there is the potential for vessel-to-vessel collisions to occur as a
result from existing shipping avoiding the marine operations, particularly across shipping lanes, near
fishing grounds and at landfall areas.
Vessels will be operating in compliance with international shipping standards, therefore, vessel
masters will be competent and adept at navigating in unfamiliar waters.
The probability of a vessel-to-vessel collision is Extremely Remote, but the consequence could be
Catastrophic.

2.3 Accidental anchoring on surface laid cable

Vessel anchors will have the potential to interact with the Cable Corridor if anchors are deployed
where the cable is surface laid, or burial is not achieved to below the anchor penetration depths. If
the cable is damaged, then existing shipping may be slightly disrupted when carrying out cable repair
operations.
However, it is very unlikely that an anchor will be deployed offshore in deeper waters and away from
anchorage areas. The probability of an anchor deployment on a surface laid cable has been
determined to be very unlikely but may occur in the event of an emergency, extreme weather
conditions or accidental deployment of an anchor.
The probability of a ships anchor interacting with the cables are Extremely Remote, but the
consequence on the ship itself and human safety could be Significant.

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Pentland Firth
Navigational Risk Assessment

2.4 Accidental snagging of fishing gear on unburied cable

Fishing vessel gear will have the potential to interact with the Cable Corridor where the cable is surface
laid, or burial is not achieved to below the fishing trawl board depths or scallop/clam dredging.
Once established, appropriate mitigation is needed to ensure the cable is suitably protected against
the type of fishing (i.e. scallop and clam dredging) and anchoring in the area. While it is advised by the
MCA and in the Mariners Handbook and as per European Subsea Cables Association (ESCA) standard
industry guidelines that fishing should be avoided across subsea cables, it is assumed that fishing may
occur across the cable once installed.
During the installation phase, there will be a designated FLO. With these services in place, there will
be a FLO monitoring body present during the installation process. The project FLO can disseminate
information to the project vessels regarding seasonal variations in fishing patterns and identifying
fishing gear/pots.
Complete fishing clearance from the installation corridor will be maintained until the post-lay surveys
have been completed. This will be co-ordinated via the FLO.
Where the cable is not surface laid, the recommended cable burial ranges between 0.4 m and 0.6 m
below the seabed (Cathie CBRA, 2020). Once installation is complete, an assessment of the potential
hazards the installed cable poses to other marine users will be submitted to Marine Scotland.
The probability of a fishing gear interacting with the cables is Extremely Remote, but the consequence
of snagging could be Catastrophic since it could cause smaller fishing vessels to bottom out.

2.5 Project vessels blocking navigational features

Project vessels have the potential to block key navigational features such as anchorages or approaches
to ports.
While the corridor does not intersect any anchorage areas there are designated anchorages to the
East of Pentland Firth (Gills Bay, Stroma Harbour). Some displacement of vessels may occur and
consideration to existing vessels anchoring may need to be carried out for the pull in operations.
However, these effects are temporary, and the cable corridors do not enter any port authority areas,
so the probability is expected to be Remote and consequence Minor.
Cable protection installation operations have longer durations and therefore frequency of blocking
navigational features during these operations have been assessed as Probable.

2.6 Extreme weather conditions

A long-range weather forecast is usually monitored hourly when conducting marine operations which
mitigates the risk of encountering any adverse or extreme weather conditions. However, the project
vessels may need to shelter in port if weather exceeds working limitations. This would mean seeking
shelter before the weather reaches the limitations of the vessel and its crew, reducing the residual
frequency. However, during the cable lay process this could mean cutting and buoying the cable in a
situation that is too dangerous to continue working.
The probability of project vessels encountering extreme weather is Extremely Remote to Remote, and
the consequence is likely to be Significant. In the risk assessment, the residual frequency is
represented by Remote; although vessels should always shelter before reaching working limits, the
weather can change unpredictably, and adverse weather could be encountered multiple times in
winter months in the high-energy waters of Pentland Firth.

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Pentland Firth
Navigational Risk Assessment

2.7 Reduced visibility

Navigating a ship in reduced visibility because of fog or heavy rain presents a set of challenges where
vessel masters should follow the relevant MGN guidelines for preventing collisions at sea.
When the ship’s officer gets information regarding such upcoming weather condition, they should take
the necessary precautions to ensure that the ship sails through reduced visibility area without
confronting any kind of collision or grounding accident. Some precautions are as follows:
▪ Keep the Fog Horn Ready: Ensure that the fog horn is working properly for the restricted area. If
the horn is air operated, drain the line prior to opening the air to the horn.
▪ Reduce Speed: Reduce the speed of the ship depending on the visibility level. If the visibility is less,
bring down the ship to manoeuvring RPM.
▪ Ensure Navigation Equipment and Light Are Working Properly: Ensure that all important navigating
equipment and navigation lights are working properly during restricted visibility. The officer on
watch must ensure that the navigation charts are properly checked for correct routeing.
Vessel masters shall be aware of their radar settings and use known objects such a channel buoys to
confirm correct calibration to ensure vessels without AIS transponders are located on radar in reduced
visibility which may lead to a collision of grounding.
The probability of project vessels encountering weather that caused reduced visibility (excluding night-
time hours) is Extremely Remote to Remote, but the consequence is likely to be Significant. The
residual risk for reduced visibility is represented as Remote in the risk assessment table.

2.8 Change in water depth – affecting safe navigation

In the event rock bags are used for the purposes of additional external cable protection, they will
generally be up to 0.7 m high. The UK Maritime and Coastguard Agency (MCA) require that any
contingency cable protection works must ensure existing and future safe navigation is not
compromised. Generally, they are prepared to accept a maximum of 5% reduction in surrounding
depth referenced to chart datum (CD) if the depth reductions do not compromise safe navigation.
However, the presence of the rock bags in water depths less than 20 m has the potential to change
the chart datum by more than 5%. Consequently, concrete mattresses (0.3 m high) will be used where
required in shallow water areas due to the lower profile of the structure.
There are two planned cable crossings, Northern Lights and Farice telecom cables. The existing
crossings are likely to be re-used, however if new crossings are required, then concrete mattresses will
be placed in approximately 55 m and 60 m water depths. Assuming a height of 0.3 m, maximum of 2
m height for each crossing, this does not exceed the 5% depth MCA requirement.
No other external cable protection is expected.

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Pentland Firth
Navigational Risk Assessment

3. RISK ASSESSMENT
3.1 Assessment
In this risk assessment the hazard has been ranked by expected risk, based on the estimated frequency
and consequence with no mitigation measures applied creating a ‘Inherent Risk’ to the project. The
exercise was repeated with compliance mitigation (Table 1-8) and industry best practice (Table 1-9)
measures which results in a residual risk allowing the hazards to be reduced to ALARP. No hazards
more than a moderate risk (see Table 1-6) are present as identified in the risk assessment.
Table 3-1 presents the risk assessment conducted on the marine operations and associated hazards.
All hazards have reached a risk level tolerable to the project through the ALARP process.

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 Inherent Risk Residual Risk
Consequence Risk Rating Consequence Risk Rating

Risk Assessment: Operation Hazard Risk Mitigation Comments

Frequency Effect on Human Displacement of Effect on Human Displacement of Frequency Effect on Human Displacement of Effect on Human Displacement of
Effect on Ship(s) Effect on Ship(s) Effect on Ship(s) Effect on Ship(s)
Safety Vessel(s) Safety Vessel(s) Safety Vessel(s) Safety Vessel(s)

Presence of project vessels 3 1 1 1 3 3 3 2 1 1 1 2 2 2

Vessel collision 2 5 5 N/A 10 10 N/A

COMP1
1 5 5 N/A 5 5 N/A Cannot assess vessel displacement if collision has occurred
COMP2
Route Clearance COMP3
Project vessels blocking navigational features 3 1 1 2 3 3 6 2 1 1 1 2 2 2
(PLGR & Boulder) BP1, BP2
BP3, BP5, BP6
BP7, BP8
Extreme weather conditions 2 2 2 2 4 4 4 2 2 2 2 4 4 4 Worst case frequency assumed (Remote)

Reduced visibility 2 2 2 2 4 4 4 2 2 2 2 4 4 4 Worst case frequency assumed (Remote)

Presence of project vessels 3 1 1 1 3 3 3 2 1 1 1 2 2 2

Vessel collision 2 5 5 N/A 10 10 N/A 1 5 5 N/A 5 5 N/A Cannot assess vessel displacement if collision has occurred

Project vessels blocking navigational features 4 1 1 2 4 4 8 2 1 1 2 2 2 4 Existing vessel anchorage must be considered
COMP1
COMP2
Accidental anchoring on unburied cable 2 2 2 2 4 4 4 1 2 2 1 2 2 1
COMP3
Shore end Operations (Cable
BP1, BP2
Pull in)
BP3, BP4 Maintain fishing clearance until after post-lay surveys (co-ordinated via
Accidental snagging of fishing gear on unburied cable 3 5 5 1 15 15 3 1 5 5 2 5 5 2
BP5, BP6 FLO)
BP7, BP8

Water depth reduction 2 1 1 1 2 2 2 1 1 1 1 1 1 1 Water depth assessed as navigable at all crossing locations

Extreme weather conditions 2 2 2 2 4 4 4 2 2 2 2 4 4 4 Worst case frequency assumed (Remote)

Reduced visibility 2 2 2 2 4 4 4 2 2 2 2 4 4 4 Worst case frequency assumed (Remote)

Presence of project vessels 3 1 1 2 3 3 6 2 1 1 1 2 2 2

Vessel collision 2 5 5 N/A 10 10 N/A 1 5 5 N/A 5 5 N/A Cannot assess vessel displacement if collision has occurred

Project vessels blocking navigational features 4 1 1 2 4 4 8 COMP1 2 1 1 1 2 2 2

COMP2
COMP3
Cable Lay Operations Accidental anchoring on unburied cable 2 2 2 2 4 4 4 BP1, BP2 1 2 2 1 2 2 1
BP3, BP4
BP5, BP6
Maintain fishing clearance until after post-lay surveys (co-ordinated via
Accidental snagging of fishing gear on unburied cable 3 5 5 1 15 15 3 BP7, BP8 1 5 5 2 5 5 2
FLO)

Extreme weather conditions 2 2 2 2 4 4 4 2 2 2 2 4 4 4 Worst case frequency assumed (Remote)

Reduced visibility 2 2 2 2 4 4 4 2 2 2 2 4 4 4 Worst case frequency assumed (Remote)

Presence of project vessels 3 1 1 1 3 3 3 2 1 1 1 2 2 2

Vessel collision 2 5 5 N/A 10 10 N/A COMP1 1 5 5 N/A 5 5 N/A Cannot assess vessel displacement if collision has occurred
COMP2
COMP3
Post Lay Trenching Project vessels blocking navigational features 4 1 1 2 4 4 8 BP1, BP2 2 1 1 1 2 2 2
BP3, BP4
BP5, BP6
Extreme weather conditions 2 2 2 2 4 4 4 BP7, BP8 1 2 2 2 2 2 2

Reduced visibility 2 2 2 2 4 4 4 2 2 2 2 4 4 4

Presence of project vessels 4 1 1 1 4 4 4 3 1 1 1 3 3 3 Longer operations so increased frequency

Vessel collision 2 5 5 N/A 10 10 N/A COMP1 1 5 5 N/A 5 5 N/A Cannot assess vessel displacement if collision has occurred
COMP2
COMP3
Articulated Pipe Installation Project vessels blocking navigational features 4 1 1 2 4 4 8 BP1, BP2 3 1 1 1 3 3 3 Longer operations so increased frequency
BP3,
BP5, BP6
Extreme weather conditions 2 2 2 2 4 4 4 BP7, BP8 2 2 2 2 4 4 4 Worst case frequency assumed (Remote)

Reduced visibility 2 2 2 2 4 4 4 2 2 2 2 4 4 4 Worst case frequency assumed (Remote)

Scottish Hydro Electric Power Distribution plc.
Pentland Firth
Navigational Risk Assessment

3.2 Conclusions
The overall vessel density across the Application Corridor is generally consistent across the Pentland
Firth and observed to be fairly low over the cable corridor itself (~1.2 vessel hours per km2). There are
horizontal and vertical patterns of more intense vessel density related to unofficial shipping lanes,
used by cargo, tanker and fishing vessels leaving and entering ports. The East-West route is mainly
traversed by cargo vessels, whilst the North-South routes are regularly used by passenger vessels.
From available RYA data, the intensity of recreational boating appears low across the study area,
though the dataset is limited particularly between KP5 and KP20, with the most activity in close vicinity
to Scrabster Harbour. The operation is not impacted by the Orkney Islands Area to Avoid.
Fishing activity is fairly consistent within the study area, with some greater activity present in a vertical
pattern perpendicular to the coast at Melvich (to the West of the study area). Moreover, creeling,
otter trawling and demersal gear are particularly common in the inshore areas where the cable is more
at risk of being impacted and snagging.
The new cable is being laid in between two existing cables which were both surface laid and have been
charted for many years. The cable corridor is therefore not getting any wider as a result of the
replacement PFE (3) cable.
The risk assessment has identified that all identified hazards have been reduced to ALARP and, with
the relevant best practice measures applied, no hazards exist that are above a moderate risk level. The
greatest risk to the existing baseline has been assessed as vessel collision, either by project vessels
interacting with the existing shipping or vice versa, however due to all vessels operating in compliance
with COLREGs the frequency has been assessed as extremely remote, lowering the overall risk rating.

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