Marine Net Gain: why it’s time to plan for marine biodiversity in offshore wind

Recently, there has been growing interest in encouraging marine biodiversity as part of offshore wind projects. It may seem strange to describe something so valuable as a ‘trend’, but it’s clear that this activity is gaining pace – and that the impetus comes from developers’ internal stakeholders as well as policy makers.

Although you’ll hear many similar terms to explain the central concepts of Marine Net Gain (MNG), they’re not interchangeable. Although MNG isn't yet a mandatory requirement, here we are using this term to cover the following two aspects:

-    Environmental enhancement, i.e. working to improve the marine environment (the quality and/or extent of habitats). Encouraging nature recovery by protecting species and habitats and reducing the pressures affecting them. Examples include habitat creation or restoration, improving water quality, and reducing disturbance. This might be done directly, in partnership with a nature conservation body, or via paying into funds where available.

-    Nature-Inclusive Design – design elements integrated into marine infrastructure that benefit biodiversity. Examples are cod tubes, which provide shelter for juvenile cod, and structures that encourage seabed-dwelling species, like these ExoReefs being trialled at the META Project. There is a lot of exciting and innovative work happening in this space.
 
Developers may also commit to both Environmental Enhancement and Nature-Inclusive Design, as in the plans Noordzeker recently announced for their “nature inclusive wind park” at IJmuiden Ver Alpha off the Netherlands.

In this article, read on to learn about:

• Drivers leading developers to plan for marine biodiversity

• Biodiversity and the leasing stage

• What marine enhancement looks like in practice and where to get project support.

Why address Marine Net Gain?

The UK is one country where Marine Net Gain is not yet written into legislation, with definitions and parameters still under discussion. However, in the UK and internationally, this looks set to become a formal requirement as the offshore wind and other industries’ use of the marine environment increases. Currently in the UK, the expectation from regulators and nature conservation bodies is that Marine Net Gain initiatives are put forward voluntarily by developers before this becomes a legal requirement. Our consultants are already answering requests for MNG support on our existing projects and a growing number of bids are including biodiversity statements.

Nature enhancement also contributes to corporate sustainability goals, biodiversity targets and satisfying ESG policies, as well as satisfying stakeholder expectations. The developer Orsted has been one front-runner, stating:

“We call on other renewable energy developers to set ambitious biodiversity goals backed up by credible action .. We call on policymakers to include stronger biodiversity criteria in renewable energy tenders, incentivising all developers to focus on value and not just short-term cost for this already highly cost-competitive energy technology.”

All this means that it’s time to get your project ready to define its MNG plans – instead of needing to catch-up at a later date.

Biodiversity and the offshore wind auction stage

In the EU, various Member States are asking for evidence that satisfies ‘non-price criteria’ in renewables auctions. Rather than focussing on price and support costs, these qualitative criteria include sustainability, innovation, and market integration.

The UK’s Leasing Round 5 in the Celtic Sea includes a similar initiative. The Crown Estate say: “We are seeking to accelerate progress towards a net positive outcome for biodiversity and improved resilience of marine ecosystems through Round 5.”

As part of their bids, Celtic Sea developers will need to include plans to demonstrate how they will create environmental (and social) value. RPS worked with The Crown Estate to produce a ‘longlist’ of interventions that bidders could take forward, but developers have the choice about what to include. The absence of formalised targets or measures of success also gives developers flexibility.

A key point is that evidence of intent to benefit the environment could increasingly be tied to agreement for lease. As such, consideration of environmental value is likely to need to be considered at an earlier stage than the onshore ‘equivalent’, Biodiversity Net Gain, which is usually undertaken during the consenting phase of onshore projects.

What does MNG mean for offshore wind developers?

Here are four practical tips on how you can start considering Marine Net Gain for your project:

1)    Costs and time
Planning for MNG means budgeting for related costs and time upfront. You’ll want to understand how much investment is required at the consenting stage as well as later when consent is achieved (the point when external funding decisions are made).

The answers will depend on your site, the local environment and the type of survey work needed, which may inform the specific Nature-Inclusive Design measures to be deployed. There is potential for economies of scale through scaled deployment of these measures across your site or as technologies become cheaper as they get more established. At a regional scale, there are opportunities for wider strategic environmental enhancement projects, which may include multiple partners to deliver large scale benefits to the marine environment.

2)    MNG is not BNG
Marine biodiversity considerations can’t be compared like-for-like with onshore Biodiversity Net Gain (BNG). Taking England as an example, BNG legislation has been in place for several years, with established metrics for measuring gains. These balance potentially adverse impacts on biodiversity as a result of a development with enhancement and biodiversity offsetting. The marine environment is much larger and more dynamic, so quantifying positive impacts on very different areas – from sandy sediment to estuarine salt marsh or nearshore oyster reefs – is complex. This means that MNG regulations may evolve to allow marine enhancement that happens both at the development site (in the form of Nature-Inclusive Design) and further removed from the project site via contribution towards projects that provide wider environmental value.

3)    Future-proofing
Some projects will proceed with caution (and uncertainty) as regulations evolve. At RPS, our Marine Consenting & Environment team take the approach of finding appropriate and proportionate solutions that are most likely to deliver measurable benefits to the marine environment, while including flexibility to allow for future-proofing. We also keep a close eye on changing legislation.

4)    A change in mindset
One of the most exciting things about this trend is the change in outlook. In the past, the Environmental Impact Assessment (EIA) process has been focussed on potential adverse impacts and mitigations, whereas MNG aims to create benefits. This subtle change in thinking provides many positive opportunities – such as aiding in the recovery and restoration of the marine environment while building developers’ reputations for taking a responsible and proactive approach.

Support for marine biodiversity measures and assessment

The Tetra Tech RPS Energy team help clients define their habitat creation, restoration and enhancement programmes and provide related support, project management and surveys. We work across the entire asset lifecycle, including preparations for lease applications and projects already in the planning stage.

In particular, we look to connect clients, partners and providers working in this space. We have built relationships with a wide network of stakeholders to support MNG provision and Nature-Inclusive Design. We are also actively involved in supporting the development of new interventions, providing the environmental baselines and expertise to ensure ecological information is considered in the designs themselves.

If you would like to speak to us about Marine Net Gain, Nature-Inclusive Design or related topics, reach out to the authors directly or complete the form below.