Oil Leak 191 EPS Part 12

What about consideration of alternatives and mitigation – this is a key part of the appropriate assessment process also – here’s what Marine Scotland say – first alternatives:

Where there is evidence that an activity will result in disturbance or injury of marine EPS, lower risk alternatives to the proposal should be considered. These could include different development scales or designs and different methods, placing the activity in an alternative area, and spatial- temporal restrictions. Activities should be timed and located, as much as possible, to avoid periods and areas where marine EPS could be present, or at least present in high densities. However, in many cases this is likely to be difficult to achieve given the unpredictable nature of cetacean distribution and abundance. Nevertheless, in some situations, suitably locating activities both spatially and temporally could be sufficient to reduce the likelihood of impact and subsequent offence.

Quite clear then – STS at sea will potentially result in dolphin disturbance. What are the options? Scale it back, do it somewhere else, avoid the periods when the dolphins are most active off the sutors. Just don’t do it here – simple.

Here’s their take on appropriate mitigation:

Some examples of mitigation measures that should be considered:

  •   Changing the project design or method, or in exceptional circumstances the scale.
  •   Technological measures for reducing noise (e.g. bubble curtains, pile sleeves, etc.).
  •   Spatial and temporal flexibility e.g. avoid siting devices in particularly sensitive areas (e.g.migration routes, feeding and breeding areas) and avoid activities that affect sensitive


  •   Minimise use of high noise emission activities (e.g. piling, percussive drilling, blasting withexplosives).
  •   Use of observation (trained Marine Mammal Observers (MMO)) and warning systems (e.g.Passive Acoustic Monitoring (PAM)) with feedback to control activity.
  •   Implementation of relevant SNH/JNCC or other guidance as appropriate.
  •   Implement ‘soft start’ for piling and other noisy activities, where possible.
  •   Adherence to the Scottish Marine Wildlife Watching Code.

Good luck with implementing any of the Bob!