The Marine Scotland document relating to EPS disturbance has a section on EPS risk assessment. We are not going to go through the whole process here, however this paragraph leapt out:
“Marine users should focus on the assessment and management of potential risk by considering practicable and proportionate alternative methods or locations to the activity, applying mitigation and following good practice guidelines.”
Consideration of alternatives is also a key component when considering the impact on the integrity of the SAC (Appropriate Assessment). In this case there is both an alternative method and location that will reduce the risk to EPS. Nigg Jetty. It is wholly within the CFPA waters and while it can be argued that the consequences of a spill there would also be significant, we believe that it can be dealt with more effectively and indeed is less likely to happen. The risk there is more acceptable, provided quantities do no increase significantly. Given the significantly higher cost of transferring oil at Nigg Jetty compared to the open sea, we would not expect this to happen.
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