Fish Safe – Safety around wind farms: the USCG’s role (Part II)

This is the second installment of two (the first can be found in the November CFN Fish Safe) focused on the USCG Navigation and Vessel Inspection Circular No. 01-19 (NVIC 01-19), which can be found at <https://www.dco.uscg.mil/Portals/9/DCO%20Documents/5p/5ps/NVIC/2019/NVIC%2001-19-COMDTPUB-P16700-4-dtd-01-Aug-2019-Signed.pdf?ver=2019-08-08-160540-483>.  The purpose of this document is “to provide guidance on information and factors the Coast Guard will consider when reviewing an application for a permit to build and operate an Offshore Renewable Energy Installation (OREI).”

Ann Backus, MS, is the director of outreach for the Harvard Chan Education and Research Center in the Department of Environmental Health at the Harvard T.H. Chan School of Public Health, Boston, MA.  She can be reached by email at abackus@hsph.harvard.edu

The concern for the safety of fishing and merchant marine vessels and crew within and near OREIs is of paramount importance.  The western North Atlantic is a busy place.  As a cooperating agency under the lead agency (the Bureau of Ocean Energy Management [BOEM]), the US Coast Guard is charged with providing expertise to the lead agency during the planning and permitting process.

 The NVIC is the USCG-produced document that outlines the areas of expertise they will address.  In NVIC 01-19, under the heading “Guidance on Conducting and Reviewing a Navigation Safety Risk Assessment” there are 16 items that address issues that the developer of an OREI must consider when undertaking a Navigation Safety Risk Assessment (NSRA).  The November column discussed items 1 through 8; this month we will focus on 9 through 16.

When creating the Navigation Safety Risk Assessment, the Coast Guard expects the OREI developer to include details about the following:

 9. Visual Navigation: The developer must assess the extent to which the wind farm structures hinder the view of other vessel traffic, hinder the view of the coastline and various navigational aids, and “limit the ability to maneuver to avoid collisions.”

10. Communications, Radar, and Positioning Systems: The developer must provide a “researched opinion” regarding whether the structures cause any electronic interference, shadowing, or any disruption of the Automatic Information System (AIS), etc., or produce any radar reflections or shadowing of a variety of communications between vessels or vessels and shore, etc.  This includes any interference that might be experienced between aircraft and air traffic control.  Three additional types of potential interference must also be researched and explained: electromagnetic interference, acoustic noise, and electromagnetic fields generated by cabling and generators.  Finally, the developer must provide an opinion as to whether any power or noise “above or below the water” poses any risk to the health of the crew.

11. Risk of Collision, Allision, or Grounding: The developer must undertake an evaluation that includes the likelihood of the type of vessel; the location; the frequency; and the likely consequences for each of the three conditions: collision, allision and grounding.

12. Emergency Response Considerations: The Coast Guard has a strong interest in being able to provide safe and successful Search and Rescue (SAR) missions.  To that end, the developer must provide a history of the SARs conducted in the vicinity of the proposed OREI with respect to how many SARs required helicopter hoists; how many were at night or under conditions of poor visibility; and how many involved helicopters or fixed wing aircraft.  The developer must also provide data on how many rescues in the vicinity required sea tows in the last ten years.

The developer must project the number of additional allision casualties that might be expected due to the presence of structures – and whether the structures provide any benefit, such as refuge for any fishing or merchant vessel.

A second type of emergency response consideration relates to pollution of the area.  The developer must describe how many marine pollution incidents the USCG responded to in the last ten years; the nature of the pollution event; and the type and number of “assets” that responded.  Finally, the developer must estimate how many “additional pollution cases would be projected due to allision with the structures.”

13. Facilities Characteristics: This section requires the developer to provide details regarding day and night marking of the area; above and below water markings; and the use of Radio Beacons and AIS, as well as whether sound signals will be in place.

Five additional conditions are listed under this heading which relate to compliance with USCG and various international standards; maintenance of navigational aids; response to discrepancies in navigational aids; and how any markings on the structures might interfere with navigational aids.

14. Design Requirements: There are five specifications under this heading that pertain to the visibility of markings; the ability to control generators and the transmission system from a local (remote) control center; the shutdown protocol; the ability to fix and maintain the wind turbine generator blades and nacelles from the command center; the design of nacelle hatches that would enable the rescue of personnel inside the turbine; and the consideration of ladders from the water to the structure that would afford stranded mariners refuge inside the structure. 

15. Operational Requirements: The operational requirements include a command center manned 24 hours per day; the availability of a chart in both the command center and the USCG District and Sector command centers specifying the Global Positioning System (GPS) location and markings of each structure in the array; and the phone number of the wind farm command center posted in each USCG command center.

16. Operational Procedures: The USCG Search and Rescue Mission Coordinator (SMC) must immediately notify the OREI command center of any allision or imminent allision with a structure, giving the position of the vessel and the identification numbers of the structures involved or at risk.  The Operational Procedures call for the command center to shut down the structure and not return it to operational status until notified by the USCG that the situation is safe and stable.  After an allision incident, the structure owner should notify the USCG if the structure is a navigational hazard.

Familiarity with the USCG role with respect to OREI siting will enable members of fishing and coastal communities to participate actively and knowledgeably in the public meetings being held by the BOEM.  For the long-term protection of marine resources and to help ensure the sustainability of the fishing industry, renewable energy and the fisheries need to co-exist.  The time and opportunity are now for fishermen and other community members to bring their concerns forward and advocate for guidance and protocols that will sustain healthy and safe fisheries.

FISH SAFE

  • Become familiar with documents pertaining to safety around wind farms.
  • Attend community and special meetings organized by BOEM and others that are designed to ensure that the fishing community has a voice.