Whilst the risk may not be crude oil, understanding impacts and response options for diesel, lubricants and hydraulics in the marine environment is imperative for the offshore wind industry. The offshore wind industry can learn and evolve from years of oil and gas development. With these lessons in mind, how ready is the offshore wind industry for a crisis?
Author: Rosie Howatt
In recent months, offshore wind developers have contacted us for advice regarding their operations, oil spill risk and subsequent response preparedness. Whilst the risk may not be crude oil, understanding impacts and response options for diesel, lubricants and hydraulics in the marine environment is imperative for the offshore wind industry.
Offshore wind is the clean green industry that everyone loves to love. With the significant global expansion of offshore wind to meet international targets, developers can now construct wind farms, further offshore, in deeper waters.
The offshore wind industry can learn and evolve from years of oil and gas development. The oil and gas industry has faced various crises in its history, such as Piper Alpha, Exxon Valdez, and Deepwater Horizon and is now working towards the energy transition and decommissioning phase.
With these lessons in mind, how ready is the offshore wind industry for a crisis?
At the end of 2020, there was a total of 35GW of global offshore wind installed, with very few bumps in the road. Political hurdles aside, the renewables industry has not yet faced a major operational crisis.
According to data collated by the G+ Global Offshore Wind Health and Safety Organisation, a global health and safety organisation for the offshore wind industry run in partnership with the Energy Institute, there were 743 incidents in 2021. So wind operations themselves are less risky, but risks are still present.
A significant amount of work goes into selecting a site for an offshore wind farm, including an Environmental Impact Assessment (EIA) with geophysical, ecological, marine mammal and bird survey results, stakeholder consultation and finalising the consenting process. The process is like oil and gas, requiring the same surveys using the same contractors.
Wind developers often consider a 'worst-case' associated with the construction process parameters itself, such as:
The 'Rochdale Envelope' approach allows meaningful EIAs to take place by defining a 'realistic worst case' scenario on the environmental impacts of a project. But does this consider the consequences of what could go wrong, really wrong?
Offshore wind farms are uncrewed, whereas oil and gas platforms, refineries and vessels are typically highly crewed. An offshore wind farm has large rotating turbines, plus the risk of an overheating gearbox or possible fire. In contrast, a drilling platform has highly flammable/ explosive and toxic products and many moving parts. So, you could say that offshore wind operations are safer. The 2020 incident rates, however, do show that there are still risks, and this is not just to people but also to the environment.
Placing offshore wind turbines in busy shipping lanes has a collision risk. Weather conditions can affect operational and maintenance activities. Innovation is required to keep costs low, and operators need to prove technology works in challenging conditions, such as floating turbines.
Positioning and placement of turbines must consider the environmental factors. However, with no associated risk of a large crude oil spill, perhaps the consequences are minor, and the operational crisis severity is not so apparent.
For the offshore wind industry, several foreseeable scenarios could result in a significant incident, including vessel impact, structural integrity, and environmental pollution.
Of the high potential incidents, such as lifting operations, working at heights and vessel activities, crew transfer vessels have the highest number of emergency response or medical evacuation injuries.
Although the priority should be to prevent, there remains a need to identify credible worst-case scenarios (WCS) in the planning stage. It is essential to ensure that arrangements with emergency response organisations can deal with situations, such as:
Below are some recent cases in the offshore wind sector that have made the news:
When considering the possible worst-case crisis scenarios for an offshore wind farm, the existing literature is slightly uninspiring. The scenarios considered include man overboard to missing persons, terrorist incidents, bomb threats, protestors, natural disasters/typhoons, and earthquakes. The literature typically clusters the scenarios into the following categories: marine, aviation, assets, and people.
The very nature of a crisis is one where we may never be able to predict what the initiating event will be, and we have learnt that you can’t always rely on the past when trying to predict the future. To truly consider what could really go wrong, it is essential to continually ask, so what? So, for example, take a hijacked vessel driven into an offshore wind farm. This incident could lead to a compromise of critical national infrastructure security and supply disruption. So what? There may be power cuts during either a cold or warm weather spell. So what? The power cuts could lead to multiple deaths due to heat exhaustion or hypothermia. And so on.
Or take a mechanical failure of a standard part, requiring industry-wide recall or a replacement programme. Assets could be offline for a prolonged duration, requiring the utilisation of other energy sources whilst the offshore wind industry gets back to normal operations. So what? This downtime could accelerate climate change impacts (more flooding, more extreme heatwaves), and the whole industry’s reputation may suffer. And so on.
In the UK the wind industry ‘guarantees confidentiality’ of incident reporting, which is different from other energy industries. There is no requirement to report any accident that does not cause death. The G+ does however undertake global incident data reporting and learning from incidents.
In 2020, there were a couple of incidents where personnel injuries occurred. One incident was on the Boruk Riggfrund 1 in Germany. The second incident was at Triton Knoll wind farm with the injury of five people aboard a Seaways heavy lifting installation vessel. According to the confidentiality guarantee, operators are not required to report these incidents.
Why is there confidentiality? Is there something to hide? Are they trying to protect a reputation? Trying to protect a reputation could damage a reputation if a crisis subsequently unfolds. Crisis management planners would treat this as a significant red flag for the offshore wind industry.
Long ago, this was a lesson learned for oil and gas, aviation, construction, and other hazardous industries. Resolving this crisis blind spot in the offshore wind industry would help protect the industry from the impacts of a future crisis. Perhaps the move of oil and gas companies to be global energy providers and the ongoing work of the G+ will help change this.
While the offshore wind industry is seemingly safer, a crisis is still unexpected, unique, and rare. COVID-19 was probably the first real test for many developers and operators, disrupting supply chains worldwide. Ørsted, one of the largest developers and divested from fossil fuels to develop wind farms, did deploy their Corporate Crisis Management Team following the initial outbreak. Reports, however, indicate that industry was largely shielded from COVID-19.
To meet targets as set by government policy and international climate commitments requires an industry-wide effort. Suppose there was a crisis for either a developer or operator/owner. Would they be treated differently by the media compared to oil and gas? Would the focus be on blame or solutions to solve the climate problem?
In the UK, the HSE set out the regulatory expectations for emergency response arrangements for the offshore renewable energy industry. Whilst this deals with the emergency, the strategic implications of an incident or emergency will still need to be handled by a developer or operators' crisis management team or 'strategic responder'. Ensuring that these responsibilities are understood, upheld, and exercised is essential for effective crisis management.
Regardless of any potential crisis for offshore wind developers or operators, the principle stands that they need to ensure they are well prepared. They should have crisis management teams ready to respond to any eventuality. Senior leadership buy-in to the apparent risks and need for preparedness may be better understood or accepted by those operating in the wind market with a background in oil and gas. A tiered spill response model for environmental risks could be implemented and shared amongst collaborative operators, as there is for oil and gas in the UK.
According to thewindpower.net there are over 2,500 developers and 2,200 operators. How many of these rigorously test and exercise their crisis plans and let their imagination run free to imagine real worst-case scenarios?
Globally, national guidelines and regulations will differ. Still, good practice for any business's crisis management and business continuity framework exists. Wind farm operators should implement, test, review, and update these periodically.
The Integrated Offshore Emergency Response – Renewables (IOER-R) Good Practice Guidelines for Offshore Renewable Energy Developments (2016) and G+ IOER (2019) provide more principles and procedures that mention more on strategic level response (crisis management).
The regulatory environment in the global offshore wind sector is unclear. Contractor-led services dilute the chain of command, should there be the need to activate a crisis management team. There are general guidelines for risk and crisis management. Companies will have policies, but are they taking their crisis preparedness seriously enough?
There will be a lot of focus on emergency response through the consenting, commissioning, and operational/maintenance phases. Oil spill response organisations (OSROs) can offer their spill response expertise to the offshore wind industry throughout the construction and operational project phases.
However, companies working in this emerging industry need also to be ready to activate their crisis teams and consider the real worst-case scenario. And we may not know how prepared the offshore wind farm industry is until a real crisis unfolds. Wind farm operators should heed the lessons learned by oil and gas operators to ensure that they are ready to respond when a crisis does happen, which inevitably it will.
Rosie has a background in offshore marine environmental consenting and holds a First-Class BSc degree in Marine Geography. She has over 12 years of project management experience and has managed the OSRL Aberdeen Team, providing accredited training courses and technical advice to OSRL Members. Rosie currently works in Southampton providing global oil spill and emergency response preparedness, including incident management system implementation. Rosie is an experienced professional in oil spill preparedness, having spent seven years with OSRL’s consultancy department, including a year’s secondment to Maersk Oil in Copenhagen. Rosie co-authored the Net Environmental Benefit Analysis IPIECA Good Practice Guide and has delivered exercises and training to European and African Regulators. She has project managed and delivered oil spill contingency plans and capability reviews for both offshore and inland operations around the world.