Corallian Colter Offshore Exploration Well - EIA Scoping Report

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1 Corallian Colter Offshore Exploration Well - EIA Scoping Report Bournemouth Borough Council comments on the potential scope of the Environmental Statement and the identification of sources of information. 20 th October 2017 Bournemouth Borough Council are aiming to be a Green Economy Leader ( and are one of the greenest cities in the UK. By definition oil exploration near to our coastline does not fit with these aims. We note that the proposal to undertake off shore oil exploration would locate a rig approx. 6.5 to 7km directly south of Bournemouth seafront. For reference this is less than half the distance from the shoreline of the nearest point of the previously proposed Navitus Bay wind farm scheme, which was to be located 16.5 km from Bournemouth beach, and generated much concern regarding the potential impacts. Consequently, we would suggest that the scope of the ES and the identification of any sources of information should include greater reference to the Secretary of State s decision in September 2015 to refuse development consent for the Navitus Bay wind farm or the reasons for that decision. Whilst it is appreciated that the scale and duration of the proposal is different from Navitus we suggest that many of these points will be pertinent to the Applicants proposed offshore oil exploration proposal and we would expect the Applicant to address these issues directly in their EIA assessment It will be important to address all phases of the development within the EIA from construction to removal. In particular the Secretary of State concluded that the scale and location of that project would affect important special qualities of the AONBs over a widespread area of coastline. Also accepted was the view that the development presented impacts that would do harm even with mitigations in place to the setting, significance and outstanding universal value for the Jurassic Coast World Heritage Site. The Secretary of State goes on to say that this development would have an adverse effect on the use and enjoyment of the World Heritage Site irrespective of the fact that the effects are essentially temporary. The Secretary of State, given the importance of the Site, and its utility and amenity value, does not consider the adverse effects, even if considered to be of a temporary nature, are acceptable. Bournemouth Borough Council s response to Navitus in the form of the Local Impact Assessment is well documented and should be cross referenced as a basis to inform the scope of any EIA. The Local Impact Reports set out a range of issues of concern, which will be relevant to this proposal. The Applicant may also want to consider the Secretary of State s conclusion regarding the Navitus Bay submission that the developer erred in some of its assessments by lessening any negative impacts on tourist-related jobs in the Dorset area. Bournemouth Borough Council will expect to see a robust analysis of tourism impacts as part of their EIA assessment. 1

2 Highlighting the importance of un-interrupted sea views to the economy of Bournemouth: In 2015 Bournemouth Borough Council commissioned an independent Seafront Visitor Survey comprising a series of 754 face to face interviews with people at different locations and times of day across Bournemouth s 5.5 mile stretch of promenade across June, July and August. This captured the views of 249 local residents, 199 day visitors and 308 holiday makers staying overnight in the resort. Interviewees were asked How important to your decision to visit the seafront/beach today are uninterrupted sea views of the bay? 84% of respondents (632 people) said this was important. 16% (122 people) said this was unimportant. The full survey results are published on the Council s website. A further almost identical survey was undertaken during 2017 with the results due to be published later this year. This time, the survey was expanded to include Poole seafront, with 756 people interviewed across 10 miles of promenade between Sandbanks and Southbourne. 273 respondents were residents, 139 were day visitors and 341 were holiday makers staying overnight in the conurbation. When asked How important to your decision to visit the seafront/beach today are uninterrupted sea views of the bay 85% said important and 15% said unimportant. During the early period of the year, prior to peak season May to September, a higher proportion of beach users will be residents. Interestingly, there is very little variation between residents and visitors in response to this question in the visitor survey. Considering the views of residents only in the 2015 survey, 84.3% considered uninterrupted sea views of the bay as important to their decision to visit the seafront a slightly higher proportion than visitors. The survey evidence points to a consistently high percentage of beach users, both residents and visitors, placing high value on uninterrupted sea views of the bay as a reason to visit the seafront. The natural amphitheatre of Poole Bay and attendant coastal sea views present the principal visitor attraction for the resort and, together with its landscape setting, the key reason for the foundation of modern Bournemouth itself back in Any changes to this, however temporary, could have a significant negative financial impact on the local tourism economy. Bournemouth Borough Council also commissions annual independent research into the volume and value of tourism to the local economy each year. The most recently published results for Bournemouth and Poole combined are for 2015 and are based on various national and regional data sets published by Visit Britain, the Office for National Statistics, Visit England and others. The Bournemouth and Poole analysis is produced by the South West Research Company. Bournemouth beach is one of the most visited in the UK, with up to 200,000 visitors on a peak day. The report identifies that Bournemouth and Poole hosted 10,749,000 holiday makers and day visitors in 2015, spending a combined 740,638,000 within the resort. This supported 941,523,000 of business turnover and 16,428 actual jobs or 10% of all employment within the conurbation. We note that the proposed EIA will only consider the exploration well scheme which, we understand, is proposed to take place in early 2018, subject to achieving consent, and last up to 45 days with 24 hour a day operation. However, should this exploration conclude successfully, we would expect a further application to undertake full scale drilling and extraction of hydrocarbons from the Colter seam. No information has been provided in the EIA Scoping Report as to the nature 2

3 or impact of long term exploitation of the site. We also note that the report identifies two further unexploited seams nearby. Clarity as to whether these potentially come into play as part of a further phase of exploration and extraction would be helpful. We believe it would be in the Applicants interest to consider undertaking an initial assessment on the basis of full mining operations and year-round site presence at this early stage in order to present a full and reasoned analysis of the impacts of this development. The EIA identifies a number of marine and coastal protected areas that will need to be considered and assessed within the EIA. We have reason to believe this list is incomplete. For example, the plans shown do not seem to indicate or reflect on the Hengistbury Head Scheduled Ancient Monument, Christchurch Harbour SSSI, Hengistbury Head SPA and SAC or the sections of cliff across Poole Bay that are SSSI and cliff top SNCI sites. The EIA should draw on the Poole and Christchurch Bay Shoreline Management Plans, the Bournemouth Cliff Management Plan, Bournemouth Seafront Strategy and Poole Seafront SPD. We note that the proposed 90 to 112 mtr tall oil rig platform may be visible for up to 35 km. This will impact on a number of heritage conservation zones, listed structures and buildings, 10 local nature reserves, 14 sites of Nature Conservation Interest, 4 sites of special scientific interest, three heathland Special Areas of Conservation and a Ramsar site within Bournemouth alone. These need to be identified and assessed within the EIA. We also note that the EIA needs to pick up on a number of national designations such as the national cycle route and coastal path which run along the seafront promenades and parts of the cliff top in Bournemouth. Parts of the seafront promenade are also designated as highways, with vehicle access between Bournemouth and Boscombe Piers. Reviewing the proposed methodology for the landscape, seascape and visual impact assessment, we note it is proposed to consult with local stakeholders on viewpoint locations. Bournemouth Borough Council would wish to be involved in this selection process and for viewpoints to cover not only the promenade but also cliff top locations within the borough. The EIA proposes to prepare photomontages of the oil rig from the agreed viewpoint locations. The Applicant should be mindful of the debate and disagreement surrounding the methodology employed by Navitus Bay in their photomontages, and present an accurate portrayal of the rig in all weather and light conditions. The Scoping Report provides no detail as to any quantitative or qualitative surveys of coastal users to support their visual impact assessment analysis. This is important in order to capture a global average assessment given people have very subjective and individual attitudes towards visual impact. The Scoping Report implies that this assessment will be done solely by the report author, a landscape architect. This approach, if we have interpreted it correctly, could leave the reports conclusions open to contention, however, an early more collaborative approach may be regarded as a more appropriate approach. 3

4 The Scoping Report outlines the potentially significant environmental impacts in Section 6. It would be useful as part of the EIA to discuss each of these impacts in relation to the identified receptor e.g. seabed disturbance and accidental hydrocarbon release would be covered under a Water and Sediment Quality chapter. Note that some impacts may be relevant to more than one receptor e.g. accidental hydrocarbon release would be relevant for both Water and Sediment Quality and Ecology. A detailed Environmental Management Plan should be produced detailing all mitigation and management measures that will be put in place throughout the lifetime of the project to demonstrate consideration of how impacts will be avoided, minimised or mitigated for. This should include the production of an Oil Spill Response Plan, which would require approval by the relevant statutory authorities at an early stage (Marine Management Organisation / Environment Agency/ Natural England). Appendix A of the report identifies an issue raised by the Department for Business, Energy and Industrial Strategy (BEIS) whereby there are no restrictions on the discharge of food waste, sewage (provided it is treated and macerated prior to discharge), as the rig will be beyond the 3 Nautical Mile limit, within which MARPOL prohibits. In addition, BEIS would not impose restrictions on the use and discharge of drilling fluids. Table 3.3 in Section 3.8 estimates a significant quantity of drilling fluids/ muds (exceeding 1.1 million kg), cuttings, cement and additives etc. being discharged to sea. Section 3.5 identifies the drilling fluids would be comprised of mostly/ if not all, biologically inert/ readily dispersible/ biodegradable products. It does not state whether these quantities would be recorded and reported (and if so who to?), or fines monitored in the sea, nor what additional chemicals may be used in the water-based mud. The release of sediment bound contaminants as a result of seabed disturbance should also be considered in the EIA. It should be noted that the borders for such legislative regulations do not apply for hydrodynamic and natural coastal processes that occur within Poole Bay. Tides, currents, south-westerly winds all contribute to a mostly clock-wise (west to east) movement of sediment within Poole Bay. It is possible that waste material discharged at this site could be transported into and around Poole Bay and its amenity beaches. Dispersion modelling discussed in Section should include a hydrodynamic element that is reflective of the known coastal processes acting within Poole Bay. The presence of the structure and associated impacts on local coastal processes (incl. sediment transport and hydrodynamics) in the area should be considered as part of the EIA. Water quality monitoring (such as fines/turbidity, O2, chemical and biological) on nearby sensitive marine receptors within the MARPOL 3NM limit should be considered during the EIA process for the drilling discharge of fines in the drilling fluid waste, and fines from the drill cuttings (expected to exceed 0.5 million kg). Water quality monitoring should also be considered prior to rig mobilisation to obtain baseline data. This would important in assessing impacts on the Poole Rocks Marine Conservation zone located approx. 4km NW of the well location, and the Maerl beds (referenced in Section 4.5) off the Purbeck coast which are sensitive to changes in water turbidity. The Maerl has been monitored historically by the National Oceanography Centre, Southampton. The impact of the scheme on the Maerl should be considered in the EIA. Monitoring would also support objective 11 of the South Marine Plan (whereby activities within or adjacent to the South Marine Plan areas must contribute to the achievement or maintenance of Good 4

5 Environmental Status under the Marine Strategy Framework Directive, and Good Ecological Status under the Water Framework Directive. Impacts on seasonal Commercial fisheries and rig transport should be considered through the EIA process. Local fishing communities at Poole (Poole District Fishermen s Association), Christchurch (Mudeford District Fishermen s Association) and the local Eastern-IFCA office should be communicated with at an early stage. Mitigation Measures for the MODU presence in Section identifies the requirements to issue Notices to Mariners. Recent work on the Bournemouth Beach Recharge in 2016 found that the appointment of local Fisheries Liaison Officers (FLO) benefitted the communication between the Council s operations and the local fishermen, where local knowledge of fishing methods/ grounds and individual contacts were key to the successful delivery of the works programme. The appointment of a non-local FLO could be seen to add bias to the project operations and communications amongst the local fishing community. The noise propagation modelling discussed in section is based on an infinite space for the sound wave to spread. It should be noted that this may not fully represent the reflective properties of Poole Bay, and the impact of the noise propagation. However, as the model struggles to extrapolate sound attenuation in the near-field, a worse-case scenario is considered, which may compensate for the initial model limitation. Timings for the Check Shot survey in section 3.6 should take into consideration the timings of migratory fish species, spawning grounds and times, and the presence of marine mammals. CEFAS and the local Eastern IFCA offices and fishing associations should be consulted on these matters. Historic England and the Local Conservation Officer / County Archaeology should be consulted during the EIA for all matters related to Archaeology and the historic environment. Due process not in gift of applicant to state what the deadline is for any response, unless the regulations being referred to empower the applicant to do so e.g. is an MMO licence already in place, Maerl impacts etc... General Point - Energy Policy Energy policy in UK is positively encouraging this type of work?, and the MMO seemed to be aligning regional process to generate and encourage offshore income. General Point Public Indemnity and Liability what arrangements are in place in insure third party risks following any pollution incident and will e.g. the applicant name the council as a joint insured party in respect of claims arising from impacts affecting e.g. the coastline. General Point Use of Jargon the applicant should be asked to explain terms such as flow tested, because we simply don t know what this means and if its highly relevant or not see Paragraph three Section 1.1 Appendix A (Consultees) is this missing any key national organisations and softer environmental groups, has the applicant determined who is on the list. The council should be given an opportunity to review the actual responses given in full and not the applicants interpretation of any responses BBC is listed as a consultee in App A noting following Of note, in late 2016, preliminary consultations were held with a number of stakeholders who would be involved in the permitting and consents process for the proposed 98/11-E well. The organisations contacted and a summary of the 5

6 issues raised are provided in Appendix A. Where relevant, these issues have been taken into consideration during the early planning stage of the project. The responses given should be reviewed in full and additional comments given. ES page 36 refers to the ES produced by November The ES programme appears to be very ambitious and is in favour of a presumption that any scoping stage is near completion. 6