Offshore renewable energy - draft decommissioning guidance: consultation

Questions

Please answer the following questions, stating your reasons.

1. This is the first version of the guidance for decommissioning offshore renewable energy installations in Scottish waters. We have, where possible, kept this in line with the UK Government’s guidance. Do you agree or disagree with this approach? 

Agree  

Disagree

Please explain your view. 

2. The main proposed variation from the UK Government’s approach is in relation to test centres. The BEIS guidance states that test centres remain responsible for ensuring decommissioning of tenants. The Scottish Government is proposing that plans for tenants should instead be approved by Marine Scotland. Do you agree or disagree with this approach? 

Agree  

Disagree

Please explain your view. 

3. Do you agree or disagree with the proposed approach and timings in relation to financial securities set out in Section 9 of the draft guidance? 

Agree  

Disagree

Please explain your view. 

4. We are proposing to include a requirement for developers to set out inflation on their securities up to the end of the project lifetime, as set out in the draft guidance document at section 8.8-8.11. Do you have any comments on this proposal? 

Please explain your view. 

5. Do you agree or disagree with the proposed timescales for review of decommissioning programmes set out in sections 5.24 – 5.29? 

Agree  

Disagree

Do you have any further comments on these suggested review schedules? 

6. We aim to ensure that all future offshore renewable energy installations have an approved decommissioning programme in place prior to construction, as this will help to manage the risk of projects going into the water without proper plans in place for removal. How achievable is this for developers? What are the challenges for different types of project? 

Please explain your view. 

7. We have provided a draft template for a decommissioning programme as this was something that was highlighted as good practice from the oil and gas sector. Do you think that a template is useful? 

Yes  

No

Do you have any suggestions on how it could be improved? 

8. It seems likely that there will be cases where part of a windfarm or array may reach the end of its lifetime earlier than others, for example where the turbines at the edge wear out more quickly than those at the centre. We would be interested to hear views on how decommissioning might work in these scenarios, for example whether non-functioning turbines could or should be left in situ until the rest of the windfarm or array can be decommissioned, and what the risks of this approach might be, or any other risks or opportunities relating to the idea of “step-down” decommissioning. 

Please explain your view. 

9. In relation to the Partial Business and Regulatory Impact Assessment, do the proposals in this consultation have any financial, regulatory or resource implications for you and/or your business (if applicable)? 

Yes  

No

If so please explain these. 

10. Do you have any further comments on the draft guidance? 

Please explain your view.