Banff Kyle EA

BANFF & KYLE DECOMMISSIONING PROJECT
CNR Project
P0009
Number:
CNR Project Banff & Kyle Decommissioning

Description: Project
Contractor:
Document Number:
P0009-CNR-EN-REP-00015 B1 113
Contract-Originator-Discipline-Document Class-5-numeric sequence Total
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Title:
REPORT - BANFF AND KYLE DECOMMISSIONING

PROGRAMME: ENVIRONMENTAL APPRAISAL - BANFF AND
KYLE EA
B1 ISSUED FOR INFORMATION 24/5/2021 KL PR PR SB
DISC. DISC. CNR

REVISION REVISION STATUS DATE ORIGINATOR CHECK APPROVAL APPROVAL
This document contains proprietary information belonging to CNR and must not be wholly or partially reproduced, nor disclosed without prior written permission from
CNR
Contract: Development of Environmental Permits & Environmental Consultancy Services
Contract Number: BFD399029
Document Title: Report - Banff and Kyle Decommissioning Programme: Environmental Appraisal Report – Banff &
Kyle EA
REVISION RECORD
Current revisions are identified on the relevant page(s) by a vertical line in the right-hand margin, adjacent to
where the revision was made. All previous revision identification has been removed.
Rev Date Revision Details

B1 24/5/2021 Issued for Information
Document Number: P0009-CNR-EN-REP-00015 Issue Date: 24/05/21

Revision: B1 Page Number: 2
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CONTENTS
TERMS AND ABBREVIATIONS 6
EXECUTIVE SUMMARY 9
Introduction and Background 9

Regulatory context 11
Decommissioning Overview 11
Proposed Schedule 11
Options for Decommissioning 12
Environmental and Societal Sensitivities 13
Impact Assessment 15
Conclusion 16
1 INTRODUCTION 17
1.1 Background 17
1.2 Regulatory Context 18
1.3 Scope and Structure 20
1.3.1 Scope of the Environmental Appraisal 20
1.3.2 Structure of the Environmental Appraisal 20
2 PROJECT SCOPE 21
2.1 Decision Making Context 21

2.2 Alternatives to Decommissioning 21
2.3 Comparative Assessment 21
2.4 Proposed Schedule 23
2.5 Decommissioning Activities 23
2.5.1 Groups 1, 2 and 4 23
2.5.2 Group 3 24
2.5.3 Structures 24
2.5.4 Group 8 26
2.5.5 Spools, Jumpers and Other Pipeline Sections 27
2.5.6 Further Remediation 27
2.5.7 Protection (Mattresse s and Grout Bags) 31
2.6 Summary of Material Inventory 31
2.7 Post-Decommissioning Activities 33
2.7.1 Clear Seabed Verification 33
2.8 Waste Management 33
2.9 Environmental Management Approach 34
3 ENVIRONMENTAL AND SOCIETAL BASELINE 35
3.1 Background 35
3.2 Summary of Environmental Surveys 35
3.2.1 Banff Habitat Asse ssment Report (2020) 35
3.2.2 Kyle Habitat Asse ssment Report (2020) 35
3.2.3 Environmental Pre-Decommissioning Report: Banff and Kyle (2020) 35
3.3 Baseline Summary 36

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3.4 Sensitive Receptors 41

3.4.1 Seabed 41
3.4.2 Conservation Sites 46
3.4.3 Other Users: Commercial Fisheries 48
3.5 National Marine Plan 55
3.5.1 GEN 1 – General planning and principle 55
3.5.2 GEN 4 – Co-existence 55
3.5.3 GEN 5 – Climate change 55
3.5.4 GEN 9 – Natural heritage 55
3.5.5 GEN 12 – Water quality and resource 55
3.5.6 GEN 14 – Air quality 55
3.5.7 GEN 21 – Cumulative impacts 56
3.5.8 Oil & Gas 1 56
3.5.9 Oil and Gas 2 56
3.5.10 Oil and Gas 3 56
3.5.11 Oil and Gas 5 56
3.5.12 Oil and Gas 6 56
4 METHODOLOGY 57
4.1 Overview 57
4.2 Approach 57
4.3 Stakeholder Engagement 57
4.4 Impact Assessment Methodology 58
5 IMPACT ASSESSMENT SCREENING AND JUSTIFICATION 60
6 IMPACT ASSESSMENT 68
6.1 Disturbance to the Seabed 68

6.1.1 Approach 68
6.1.2 Sources of Potential Impacts 68
6.1.3 Effects on Sensitive Receptors 76
6.1.4 Cumulative and Transboundary Impacts 80
6.1.5 Potential Impacts to Protected Sites 80
6.1.6 Mitigation Measures 81
6.1.7 Residual Impact 82
6.2 Physical Presence of Infrastructure Decommissioned in situ in Relation to Other Sea Users 83
6.2.1 Sources of Potential Impacts 83
6.2.2 Effects on Sensitive Receptors 83
6.2.3 Cumulative and Transboundary Impacts 85
6.2.4 Mitigation Measures 85
6.2.5 Residual Impact 86
7 CONCLUSIONS 87
8 REFERENCES 88
APPENDIX A ITEM INVENTORY 91
Appendix A.1 Group 1 Pipelines 91

Appendix A.3 Group 3 Flexible Flowline 91
Appendix A.5 Structures 92
Appendix A.6 Group 8 STL Piles 93

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Appendix A.7 Spools, Jumpers and SSIVs 93

Appendix A.8 Pipeline Structures 95
Appendix A.9 Stabilisation Materials 95
APPENDIX B CNRI POLICIES 96
Appendix B.1 CNRI Health & Safety Policy 96

Appendix B.2 CNRI Environmental Management Policy 97
APPENDIX C ENVID 98
APPENDIX D ENERGY AND EMISSIONS SUMMARY 101
Appendix D.1 Energy and emissions by project activity 101

Appendix D.2 Offshore transport energy and emissions 101
APPENDIX E PIPELINE EXPOSURES SUMMARY 102
Appendix E.1 Survey Assessment Summary Reports 102

Appendix E.1.1 PL1546 102
Appendix E.1.6 PL1799.1-8 113

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TERMS AND ABBREVIATIONS

Abbreviation Text in full
AIS Automatic Identification System
ALARP As Low As Reasonably Practicable
BAT Best Available Technology
BEIS Business, Energy and Industrial Strategy
CA Comparative Assessment
CATS Central Area Transmission Systems
CNRI Canadian Natural Resources International
CNS Central North Sea
CO2 Carbon dioxide
CoP Cessation of Production
CPUE Catch per Unit Effort
cm Centimetre
°C Degree(s) Celsius
CSV Construction Support Vessel
DECC Department of Energy and Climate Change
DoB Depth of Burial
DP Decommissioning Programme
DSV Dive Support Vessel
DUTU Dynamic Umbilical Termination Unit
E East
EA Environmental Appraisal
EHC Electrohydraulic Control
EIA Environmental Impact Assessment
EMS Environmental Management System
ENVID Environmental Impact Identification
EPS European Protected Species
EU European Union
EUNIS European Nature Information System
FAO Food and Agriculture Organisation
FPSO Floating, Production Storage and Offloading vessel
FSO Floating Storage and Offloading vessel
GJ Gigajoule
HSE Health, Safety and Environment
ICES International Council for the Exploration of the Seas

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in Inch
JNCC Joint Nature Conservation Committee
kg Kilogrammes
km Kilometre
km2 Square kilometre
KP Kilometre Point
KPI Key Performance Indicator
m Metre
MARPOL Marine Pollution
MCDA Multi Criteria Decision Analysis
MCZ Marine Conservation Zone
μg/g Micrograms per gram
mm Millimetre
MMO Marine Management Organisation
MPA Marine Protected Area
MPE (Norwegian) Ministry of Petroleum and Energy
N/A Not Applicable
NCMPA Nature Conservation Marine Protected Area
NE Northeast
nm Nautical mile
NMP National Marine Plan
NNS Northern North Sea
NORM Naturally Occurring Radioactive Material
NW Northwest
OD Outer Diameter
OGA Oil & Gas Authority
OGUK Oil & Gas UK
OPRED Offshore Petroleum Regulator for Environment & Decommissioning
OPEP Oil Pollution Emergency Plan
OSPAR Oslo Paris Convention – Convention for the Protection of the Marine
Environment of the North East Atlantic
PAH Polycyclic aromatic hydrocarbon
PCB polychlorinated biphenyl
PL Pipeline
PLEM Pipeline End Manifold
PMF Priority Marine Features
ppm parts per million

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PWA Pipeline Works Agreement

ROV Remotely Operated Vehicle
SAC Special Area of Conservation
SACFOR Super abundant, Abundant, Common, Frequent, Occasional, Rare
SAL Submerged Anchor Loading
SAM Subsea Accumulator Module
SCOS Special Commission on Seals
SDU Subsea Distribution Unit
SEPA Scottish Environmental Protection Agency
SFF Scottish Fishermen’s Federation
SHE Safety, Health, Environment
SMRU Sea Mammal Research Unit
SNH Scottish National Heritage
SOPEP Shipboard Oil Pollution Emergency Plans
SOSI Seabird Oil Sensitivity Index
SPA Special Protection Areas
SSIV Sub-Surface Isolation Valve
SSS Side Scan Sonar
STL Subsea Turret Loading
SW Southwest
Te Tonne
TFSW Trans Frontier Shipment of Waste
THC Total Hydrocarbon Concentration
TOOPEP Temporary Operation Oil Pollution Emergency Plan
TPFP Teekay Petrojarl Floating Production UK Limited
TUTU Topside Umbilical Termination Unit
UKBAP United Kingdom Biodiversity Plan
UKCS United Kingdom Continental Shelf
UKOOA United Kingdom Offshore Operators Association
VMS Vessel Monitoring System
WHPS Wellhead Protection Structures

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EXECUTIVE SUMMARY
Introduction and Background
In accordance with the Petroleum Act 1998, Canadian Natural Resources International (UK) Limited (CNRI),
on behalf of Teekay Petrojarl Floating Production UK Limited (TPFP) and the Banff and Kyle JV Partners, are
applying to the Department for Business, Energy and Industrial Strategy (BEIS) to obtain approval for the
decommissioning of the Banff and Kyle subsea infrastructure and pipelines. In June 2020, CNRI began the
process to permanently cease production from these Fields.
Figure 1-1 Location of the Banff and Kyle Fields

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Both Fields produced via the leased Petrojarl Banff Floating Production Storage and Offloading vessel (FPSO)
and the Apollo Spirit Floating Storage and Offloading vessel (FSO). In Q4 of 2019 CNRI, TPFP and Altera
Infrastructure (formerly a part of TPFP) created a combined project team to safely execute the release of the
FPSO and FSO. The FPSO, FSO and associated risers were subject to a separate combined
Decommissioning Programme (DP/163/19) as part of the decommissioning strategy and are independent of
the remaining infrastructure to be decommissioned. FPSO float off occurred in August 2020. The remaining
activities of the Banff and Kyle decommissioning strategy include the decommissioning of the Banff and Kyle
subsea installations and pipelines and are covered by this EA, in support of the associated DP.
The Banff Field is located in Blocks 29/2a and 22/27a in the UK Sector of the Central North Sea (CNS) due
east of Aberdeen and 191 km from the nearest point of land. The Kyle Field is located in Blocks 29/2c and
29/2h in the UK Sector of the CNS also due east of Aberdeen, 192 km from the Scottish mainland, in
approximately 90 m water depth (see Figure 1-1).
There is one drill centre in the Banff area and two drill centres supporting the Kyle Fields (North Kyle and South
Kyle). North and South Kyle drill centres are approximately 3 km apart and are linked by an 8” production
pipeline and an Electrohydraulic Control (EHC) umbilical. A 4” gas lift pipeline connects the Kyle North Drill
Centre to the Banff Drill Centre which was historically tied back to the FPSO. A gas export pipeline also
connected the Banff infrastructure to the Central Area Transmission System (CATS) export pipeline. A
disconnected pipeline and umbilical also linked the Curlew Field (~2 km south of Kyle) to South Kyle and as
such is also part of the decommissioning scope; this pipeline and umbilical are located partly within Block 29/7
(see Figure 1-1). The schematic in Figure 1-2 shows the current layout of the Banff and Kyle Fields.
Figure 1-2 Banff and Kyle Field illustration

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Regulatory context
The Petroleum Act 1998 (as amended by the Energy Act 2008) governs the decommissioning of offshore oil
and gas infrastructure, including pipelines, on the United Kingdom Continental Shelf (UKCS). The Petroleum
Act requires the operator of an offshore installation or pipeline to submit a draft DP for statutory and public
consultation, and to obtain approval of a DP from the Offshore Petroleum Regulator for Environment &
Decommissioning (OPRED), part of BEIS, before initiating decommissioning work. The DP should outline in
detail the infrastructure being decommissioned and the method by which the decommissioning will take place
(CNRI, 2021). The primary guidance for offshore decommissioning was updated and published by BEIS in
2018 (and updated in 2020), details the need for an Environmental Appraisal (EA) and a Comparative
Assessment (CA) to be submitted in support of the DP. For the EA, the Guidance describes a proportionate
process that culminates in a streamlined EA Report which focuses on screening out of non-significant impacts
and presents a detailed assessment of potentially significant impacts. The CA is a detailed process that
involves a weighted assessment of various decommissioning options against key criteria identified by the
Guidance.
The Scottish National Marine Plan (NMP) has been adopted by the Scottish Government to help ensure
sustainable development of the marine area. With regards to decommissioning, the Plan states that “where
re-use of oil and gas infrastructure is not practicable, either as part of oil and gas activity or by other sectors
such as carbon capture and storage, decommissioning must take place in line with standard practice, and as
allowed by international obligations. Re-use or removal of decommissioned assets from the seabed will be
fully supported where practicable and adhering to relevant regulatory process”. CNRI present this EA in
alignment with the aims of the Plan.
Decommissioning Overview
The decommissioning strategy for the Banff and Kyle Fields has been split into two DPs, which cover the
following:
1. The release and float-off of the Petrojarl Banff FPSO and Apollo Spirit FSO (DP/163/19; CNRI 2020);
2. The decommissioning subsea infrastructure and pipeline structures within the Banff and Kyle fields
(associated with this EA), and covers:
 all subsea installations (including trees and wellhead structures);
 eight Subsea Turret Loading (STL) piles;
 spools, jumpers and SSIVs;
 drill cuttings;
 stabilisation materials;
 pipelines, flexible flowlines and umbilicals; and
 remediation associated with decommissioning of the above.
This Environmental Appraisal (EA) report covers the environmental impacts of the decommissioning activities
anticipated for the different item groups listed above. The Comparative Assessment (CA) presents the
emerging decommissioning options for the pipelines and flowlines and for the eight pile structures. The EA
only considers the impacts of these emerging options.
Proposed Schedule
The precise timing of the decommissioning activities is not yet confirmed and will be subject to market
availability of cost-effective removal services and contractual agreements. The potential activity window for
the Banff and Kyle subsea decommissioning activity is between 2022 and 2026.

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Options for Decommissioning

All of the Banff and Kyle Field subsea infrastructure was assessed for decommissioning against the Guidance
Notes: Decommissioning of Offshore Oil and Gas Installations and Pipelines (BEIS, 2018). The recommended
Comparative Assessment (CA) process was undertaken following this Guidance. In accordance with normal
practice for the Scoping phase of the CA, equipment was organised into groups of items with similar
characteristics, facilitating greater efficiency in processing the latter phases of the CA. The guidance identifies
items which must be fully removed and some categories of pipelines which may be left decommissioned in
situ subject to CA. Once the equipment groups designated for full removal were identified the remaining
groups were assessed further.
The CA groups which were considered for Decommissioning are outlined in Table 1-1 and further details are
provided in the accompanying Banff and Kyle Field CA Report. Table 1-1 also indicates whether the
infrastructure was scoped in or out of CA. Where only one option was identified for decommissioning the
group was scoped out of CA. The emerging options are in bold and are covered in greater detail in this EA.
Only Groups 1, 2, 4 and 8 were carried through the CA process as all other groups were identified for full
removal.
Table 1-1 CA Groups Assessed, Scoping Decision and Emerging Options
CA Group Subsea Infrastructure Scoping Decommissioning Options Considered

No. Description Decision (emerging option in bold)
Rigid Pipelines, Trenched Scoped in Option 2a: Cut and Lift w ith De-Burial
and Buried Option 4a: Rock Placem ent over Ends /
Exposures
1
Option 4c: Remove Exposures
Option 5: Remove Ends and Remediate Snag
Hazards
Flexibles / Umbilicals Scoped in Option 2b: Reverse Reel w ithout De-Burial

Trenched and Buried Option 4a: Rock Placem ent over Ends /
2 Exposures
Hazards
Flexibles / Umbilicals, Scoped out Full Rem oval

3 Surface Laid
and Rock Covered Option 4a: Rock Placem ent over Ends /
4 Exposures
Hazards
5 Spools and Jumpers Scoped out Full Rem oval
Subsea Installations Scoped out Full Rem oval

6
(Structures)
7 Protection / Stabilisation Scoped out Full Rem oval
STL piles Scoped in Option 2c: Reverse Installation w ith De-Burial

Option 3a: Rock Cover Exposed Piles and Chains
8
Option 5: Leave in situ – Rem ove Piles to Below
the Seabed

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Environmental and Societal Sensitivities

The key environmental and societal sensitivities in the Banff and Kyle area are summarised in Table 1-2.
Table 1-2 Env ironmental and Societal Sensitivities in the Banff and Kyle Area
Conservation Interests
No adult ocean quahog (>1 cm) were recovered within samples or observed during survey footage of the
Banff and Kyle Fields (Fugro, 2020a, 2020b).
The habitat ‘Seapens and burrowing megafauna’ was present within both the Banff and Kyle Field survey
areas. According to the SACFOR classification, seapen presence ranged from ‘rare’ to ‘common’. Faunal
burrows between 3-15 cm ranged from either ‘frequent’ to ‘abundant’ at the four sites where they were
present (Fugro, 2020a). Both ‘Burrowed mud’ and ‘Seapens and burrowing megafauna in circalittoral fine
mud’ are also considered PMFs. No Annex I protected features were observed in the area.
Conservation Sites
The Banff Field infrastructure is partly located within the East of Gannet and Montrose Fields NCMPA. The
site is ~10 km due north of the Kyle Fields. The site is designated for the protection of ocean quahog
aggregations and deep-sea muds. The next closest protected sites are located >50 km from the Banff and
Kyle Fields (Scanner Pockmark SAC, Fulmar MCZ).
Conservation Species
Harbour porpoise, short beaked common dolphin, white-beaked dolphin, Atlantic white-sided dolphin and
minke whale are known to be visitors to the waters surrounding the project area (Reid et al., 2003; Hammond
et al., 2017). All of these species are both European Protected Species (EPS) and are covered by the UK
Biodiversity Action Plan (BAP).
Both grey and harbour seal densities are very low (0-1 individuals per 25 km 2) across the Banff and Kyle
area due to its distance from shore (Russell et al., 2017). Both seal species are Annex II species.
Benthic Environment
The Banff Field is located partly within A5.27 ‘Deep circalittoral sand’, and also within an area of A5.37
‘Deep circalittoral mud’. The Kyle Field is almost exclusively located within A5.37 ‘Deep circalittoral mud’.
Directly to the south of the Banff Field is a small patch of A5. 15 ‘Deep circalittoral coarse sediment’
(EMODnet, 2019). Side-scan sonar data revealed regions of seabed which had higher sonar reflectivity
corresponded with regions of A5.44 ‘Circalittoral mixed sediment’ in the Banff Field (Fugro, 2020a).
Benthic fauna composition was similar between the Banff and Kyle Fields. The dominant taxa observed
within both the sandy and mixed substrate at the Banff Field, were seapens, hermit crabs and anemones
(Fugro, 2020a). Sea urchins were additionally amongst the dominant species within the Kyle Field (Fugro,
2020b). Bioturbation was evident across both survey areas (Fugro 2020a, 2020b). The ‘ Seapens and
burrowing megafauna in circalittoral fine mud’ habitat, as described above, was present at both the Banff
and Kyle Fields.
Though no cuttings piles are evident in the project area, sediment contamination levels indicate the presence
of historic piles (Fugro, 2020c).
Fish
The project area is located within the high intensity spawning grounds of mackerel and Norway pout as well
as the spawning grounds of cod, lemon sole and sandeel. Additionally, the following species use the area
as nursery grounds: anglerfish, blue whiting, cod, European hake, haddock, herring, ling, mackerel, Norway
pout, plaice, sandeel, spurdog and whiting (Coull et al., 1998; Ellis et al., 2012).
Aires et al. (2014) provides modelled spatial representations of the predicted distribution of 0 age group fish.
The modelling indicates the presence of juvenile fish (less than one year old) for multiple species: anglerfish,

Kyle EA
blue whiting, European hake, haddock, herring, mackerel, horse mackerel, Norway pout, plaice, sprat, and
whiting. Across the project area, the probability of juvenile fish aggregations occurring is low (<0.15).
Seabirds
According to the density maps provided in Kober et al. (2010), the following species could be found within
the project area: northern fulmar, Manx shearwater, European storm-petrel, northern gannet, Arctic skua,
great skua, black-legged kittiwake, great black-backed gull, common gull, lesser black-backed gull, herring
gull, Arctic tern, common guillemot, razorbill, little auk, Atlantic puffin and pomarine skua. Seabird Oil
Sensitivity Index (SOSI) identifies areas at sea where seabirds are likely to be mos t sensitive to surface
pollution (Webb et al., 2016). Seabird vulnerability in Blocks 22/27, 29/2 and 29/7 is low throughout the year
with no data for November. Block 29/11 experiences a Very High SOSI value in the months of September
and October (Webb et al., 2016). The risk of an oil spill from the proposed operations in the project area is
considered remote and therefore the overall risk to birds is considered negligible.
Commercial Fisheries
The Banff and Kyle infrastructure lies in International Council for the Exploration of the Seas (ICES)
Rectangles 42F1 and 43F1 (Scottish Government, 2020). The waters comprising the Banff and Kyle are
fished for a variety of species by both UK and foreign vessels. ICES rectangle 42F1 has predominantly
been targeted for shellfish in recent years, whilst the adjacent ICES rectangle 43F1 experiences a much
greater amount of demersal fishing. For the last five fishing years (2015-2019 inclusive), the total landings
value was greater in ICES rectangle 42F1 than 43F1 by £2,383,217, and the live weight of those landings
were greater by approximately 694 Te. This observation reflects the dramatically larger tonnage of shellfish
species caught in ICES rectangle 42F1, comprising >50% of the total landings live weight in 2019. The total
annual landings for ICES rectangles 42F1 and 43F1 were ≤1% of the total landings within the UKCS for
each of the five most recent fishing years (Scottish Government, 2020).
In 2019 fishing effort in ICES rectangle 42F1 was highest in January, March and November, accounting for
51% of the total number of days fished, however overall effort was relatively low for 42F1 (Scottish
Government, 2020). Comparatively, fishing effort in ICES rectangle 43F1 was much lower. In total there
were 28 days of fishing effort in 2019 in 43F1 which is deemed to be very low (Scottish Government, 2020).
Both in 2018 and consistently in previous years, fishing effort has been greater in rectangle 42F1 compared
to 43F1. Trawls were the most utilised gear in rectangle 42F1 and 43F1. In total, trawls contributed 99% of
the total fishing effort in rectangle 42F1. In rectangle 43F1 approximately 86% of total fishing effort was
from trawls with the remainder being attributed to seine nets (Scottish Government, 2020).
Other Sea Users
The Banff and Kyle infrastructure is located in a mature area of the CNS with extensive oil and gas
development. There are five oil and gas surface structures within 40 km of the project area. The Banff and
Kyle infrastructure is located in areas of either low or very low shipping intensity (OGA, 2016).
There are no designated areas for military activities occur in the vicinity of the Banff and Kyle infrastructure
(NMPi, 2020). There are no dangerous wrecks and no active cables in the vicinity of Banff and Kyle (NMPi,
2020). The North Sea Link electricity interconnector between Norway and the UK is currently under
construction. It will pass approximately 2 km from the Kyle Field (NMPi, 2020). The cable will be operational
by 2021 (North Sea Link, 2020) and therefore should not coincide with the proposed decommissioning.

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Impact Assessment
This EA Report has been prepared in line with the OPRED Decommissioning Guidelines and with Decom
North Sea’s EA Guidelines for Offshore Oil and Gas Decommissioning. The environmental impact assessment
has been informed by several different processes, including the identification of potential environmental issues
through project engineer and marine environmental specialist review in an Environmental Identification
(ENVID) screening workshop and consultation with key stakeholders. The ENVID workshop discussed the
proposed decommissioning activities and any potential impacts these may pose. The impacts assessed were
as follows:
 Emissions to air;
 Disturbance to the seabed;
 Physical presence of vessels in relation to other sea users;
 Physical presence of infrastructure decommissioned in situ in relation to other sea users;
 Discharges to sea;
 Underwater noise associated with general decommissioning activities;
 Resource use;
 Onshore activities;
 Waste; and
 Unplanned events
Of the ten potential impacts, only impacts associated with ‘Disturbance to seabed’ and ‘Physical presence of
infrastructure decommissioned in situ in relation to other sea users’ were screened in for further assessment
based on the potential severity and / or likelihood of their respective environmental impact.
Further reasoning for why the remaining eight impacts were scoped out, and mitigation measures that will be
applied against each aspect, are presented within the main body of the EA. The intention is that such
measures should remove, reduce or manage the impacts to a point where the resulting residual significance
is reduced to ‘as low as reasonably practicable’ (ALARP). The potential impacts considered are as follows:
Disturbance to seabed was investigated further as a potential impact due to the nature of the proposed
activities and proximity to the sensitive seabed habitats of the East of Montrose and Gannet Nature
Conservation Marine Protection Area (NCMPA). Of key importance is the recovery of habitats and benthos
following temporary disturbance and the area of seabed expected to be affected by permanent disturbance.
The following measures have been or will be taken in order to reduce as far as possible potential impacts on
the environment from the various decommissioning activities:
 All activities which may lead to seabed disturbance will be planned, managed and implemented in such a
way that disturbance is minimised;
 Careful planning, selection of equipment, and management and implementation of activities;
 A debris survey will be undertaken at the completion of the decommissioning activities. Any debris identified
as resulting from oil and gas activities will be recovered from the seabed where possible;
 Rock armour will be placed by a fall pipe vessel equipped with an underwater camera on the fall pipe. This
will ensure accurate placement of the rock armour and reducing unnecessary spreading of the rock armour
footprint and ensuring that minimum safe quantity or rock is used; and,
 Clear seabed verification will ensure there is no residual risk to other sea users. Non-intrusive verification
techniques will be considered in the first instance, but if deemed necessary, seabed clearance may require
conventional overtrawl survey methods, in agreement with OPRED and fishing bodies.

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Physical presence of infrastructure decommissioned in situ in relation to other sea users was investigated
as a potential impact on commercial fisheries. Of key importance was understanding the utilisation of the Banff
and Kyle Fields for commercial fishing purposes and the risk this infrastructure decommissioned in situ
presented as a snagging hazard.
The following measures have been or will be taken in order to reduce as far as possible potential impacts on
the environment from the various decommissioning activities:
 The Banff and Kyle Fields’ subsea infrastructure is currently shown on Admiralty Charts, the FishSafe
system and the OGA Infrastructure data systems (OGA Open Data). Once decommissioning activities are
complete, updated information (i.e. which infrastructure remains in situ and which has been removed) will
be made available to allow the Admiralty Charts and the FishSafe system to be updated;
 Any exposures / cut flowline ends will undergo rock placement to ensure they are overtrawlable to active
fishing gears;
 Any objects dropped during decommissioning activities will be removed from the seabed where
appropriate;
conventional overtrawl survey methods. Where there is evidence of residual snagging hazards (e.g. any
spans, berms, dropped objects, etc.), then intervention in the form of overtrawling to re-level the seabed
or the addition of rock placement will be discussed with OPRED, and implemented as appropriate; and
 CNRI recognise their commitment to monitor any infrastructure decommissioned in situ and therefore
intend to set up arrangements to undertake post-decommissioning monitoring. The frequency of the
monitoring that will be required will be agreed with OPRED and future monitoring will be determined
through a risk-based approach based on the findings from each subsequent survey. During the period
over which monitoring is required, the status of the infrastructure decommissioned in situ would be
reviewed and any necessary remedial action undertaken to ensure it does not pose a risk to other sea
users.
Conclusion
This EA has considered the Scottish National Marine Plan, adopted by the Scottish Government to help ensure
sustainable development of the marine area. CNRI consider that the proposed decommissioning activities are
in alignment with its objectives and policies.
Having reviewed the project activities and taken into consideration: the remote offshore locati on of the Banff
and Kyle Fields; that the activities will have a small area of impact; that the benthos are likely to have a degree
of natural resilience to sediment suspension; the availability of similar habitat within the context of the wider
North Sea, as well as the undertaking of mitigation measures to limit this impact, there is not expected to be a
significant impact on the seabed environment or any European or nationally designated protected sites in
proximity to the activities.
The Banff and Kyle Fields are generally not heavily fished and what little trawling activity there is in the area,
is mostly concentrated along pipelines without identified exposures. Pipelines which do presently have
exposures along their lengths will be appropriately remediated during decommissioning thereby no snagging
risk should remain to fisheries. Overall, there is not expected to be an impact on commercial fisheries from
infrastructure decommissioned in situ.

Kyle EA
1 INTRODUCTION
1.1 Background
In accordance with the Petroleum Act 1998, Canadian Natural Resources International (UK) Limited (CNRI),
on behalf of Teekay Petrojarl Floating Production UK Limited (TPFP) and the Banff and Kyle JV Partners, are
applying to the Department for Business, Energy and Industrial Strategy (BEIS) to obtain approval for the
decommissioning of the Banff and Kyle subsea infrastructure and pipelines. In June 2020, CNRI began the
process to permanently cease production from these fields.
Figure 1-1 Location of the Banff and Kyle Fields

Kyle EA
The Banff Field infrastructure is located in Blocks 29/2a and 22/27a in the UK Sector of the Central North Sea
(CNS) due east of Aberdeen,191 km from the nearest point of land and in water of a depth of approximately
95 m. The Kyle Field infrastructure is located in Block 29/2c and 29/2h in the UK Sector of the Central North
Sea some also due east of Aberdeen, and 192 km from land, in approximately 90 m water depth (Figure 1-1).
There is one drill centre in the Banff area and there are two drill centres in the Kyle areas (North Kyle and
South Kyle). North and South Kyle are approximately 3 km apart and are linked by an 8” production pipeline
and an EHC umbilical. A 4” gas lift pipeline connects the Kyle North Drill Centre to the Banff Drill Centre which
historically tied back to the FPSO. A gas export pipeline also connected the Banff infrastructure to the Central
Area Transmission System (CATS) export pipeline. A disconnected pipeline and umbilical also linked the
Curlew Field (~2 km south of the Kyle Field) to South Kyle and as such is also part of the scope of this DP.
The disconnected pipeline and umbilical are located within Block 29/7 (see Figure 1-1). The schematic in
Figure 1-2 shows the layout of the Banff and Kyle Fields. Prior to float-off, produced gas was exported from
the Petrojarl Banff Floating Production Storage and Offloading vessel (FPSO) via the CATS pipeline to the
CATS Terminal in Seal Sands, Teesmouth. Their former location is indicated by the two cardinal buoys and
single special marker, as shown in Figure 1-2.
The Banff Field came online in 1996. CNRI International (UK) Limited (hereafter, "CNRI") brought the Kyle
Field online in 2000, and initial production was through the Curlew FPSO. CNRI took over operatorship of the
Banff Field in 2003 and the following year production from the Kyle Field K14 well was tied back to Banff
infrastructure. In 2005 the remaining Kyle Field wells were tied back to Banff. Both Fields produced via the
leased Petrojarl Banff FPSO and the Apollo Spirit Floating Storage and Offloading vessel (FSO). In Q4 of
2019, with a natural decline in production and a drop in commodity price CNRI, TPFP and Altera Infrastructure
(formerly a part of TPFP) created a combined project team to safely execute the release of the FPSO and
FSO. The FPSO, FSO and associated risers were subject to a separate combined Decommissioning
Programme (DP/163/19) as part of the decommissioning strategy and are independent of the remaining
infrastructure to be decommissioned. Cessation of Production (CoP) approval was granted in March 2020.
CoP took place in June 2020 and FPSO and FSO float off occurred in August 2020.
1.2 Regulatory Context

The Petroleum Act 1998 (as amended by the Energy Act 2008) governs the decommissioning of offshore oil
and gas infrastructure, including pipelines, on the United Kingdom Continental Shelf (UKCS). The
responsibility for ensuring compliance with the Petroleum Act 1998 rests with Department of Business, Energy
and Industrial Strategy (BEIS) and is managed through its regulatory body the Offshore Petroleum Regulator
for Environment and Decommissioning (OPRED). OPRED is the Competent Authority on decommissioning
in the UK for OSPAR purposes and relevant legislation. The Petroleum Act requires the operator of an offshore
installation or pipeline to submit a draft DP for statutory and public consultation, and to obtain approval of a
DP from OPRED, part of BEIS, before initiating decommissioning work. The DP should outline in detail the
infrastructure being decommissioned and the method by which the decommissioning will take place (CNRI,
2021).
Formal Environmental Impact Assessment (EIA) to support a DP is not explicitly required under existing UK
legislation. However, the primary guidance for offshore decommissioning that was updated and published by
BEIS in 2018 (and updated in 2020), detailed the need for an EA to be submitted in support of the DP. This
guidance describes a proportionate EA process that culminates in a streamlined EA Report which focuses on
screening out of non-significant impacts and presents a detailed assessment of potentially significant impacts.
In terms of activities in the CNS, the Scottish National Marine Plan has been adopted by the Scottish
Government to help ensure sustainable development of the marine area. With regards to decommissioning
the Plan states that “where re-use of oil and gas infrastructure is not practicable, either as part of oil and gas
activity or by other sectors such as carbon capture and storage, decommissioning must take place in line with
standard practice, and as allowed by international obligations. Re-use or removal of decommissioned assets
from the seabed will be fully supported where practicable and adhering to relevant regulatory process”. As
part of the conclusions to this assessment (Section 7), CNRI have considered the broader aims of the Plans
and have made a statement on alignment with the aims.

Document Title: Report - Banff and Kyle Decommissioning Programme: Environmental Appraisal Report
Figure 1-2 Banff and Kyle Field illustration
Document Number: BFD399029-XDS-EN-REP-00002 Issue Date: 20/05/21

Contract: Development of Environmental Permits & Environmental Consultancy Ser vices
1.3 Scope and Structure
1.3.1 Scope of the Environmental Appraisal

The decommissioning strategy for the Banff and Kyle Fields has been split into two DPs, which cover:
1. The release and float-off of the Petrojarl Banff FPSO and Apollo Spirit FSO (DP/163/19; CNRI, 2020);
2. The decommissioning subsea infrastructure and pipeline structures within the Banff and Kyle fields
(associated with this EA), and covers:
 all subsea installations (including trees and wellhead structures);
 Subsea Turret Loading (STL) piles;
 spools, jumpers and SSIVs;
 eight subsea pile structures;
 drill cuttings;
 stabilisation materials;
 pipelines, flexible flowlines and umbilicals; and
 remediation associated with decommissioning of the above.
This Environmental Appraisal (EA) report covers the environmental impacts of the decommissioning activities
anticipated for the different item groups listed above. The Comparative Assessment (CA) presents the
emerging decommissioning options for the pipelines and flowlines and for the eight pile structures. The EA
only considers the impacts of these emerging options.
This EA does not cover well decommissioning that will be undertaken prior to the commencement of the
decommissioning activities. Flushing and cleaning operations have already occurred within the Fields; these
activities are additionally not within scope of the EA and have been covered by the appropriate permits. The
Xmas trees and wellhead structures are included as part of the subsea infrastructure for consideration in the
respective DPs for these fields; however, these installations will be removed as part of well decommissioning
operations within the well abandonment campaign and will be covered by that permitting regime. Assessment
of impacts from onshore energy use and atmospheric emissions for well decommissioning activities will be
included in license applications for appropriate onshore disposal facilities. As the assessment of the removal
of these subsea installations will be captured within the relevant permits, they are considered outwith the scope
of this EA. This activity will be carried out as part of the preparatory work preceding decommissioning, under
existing field operational permits. Further detail about the infrastructure to be decommissioned is provided in
Section 2.
1.3.2 Structure of the Environmental Appraisal

This EA report describes the potential environmental impacts of the proposed activities associated with the
Banff and Kyle decommissioning and to demonstrate the extent to which these can be mitigated and controlled
to an acceptable level. This is achieved in the following Sections:
 The process by which the selected decommissioning strategy has been established (Section 2);
 A description of the proposed decommissioning activities (Section 2);
 A summary of the baseline sensitivities and receptors relevant to the assessment area that support this
EA (Section 3);
 The methodology used to carry out the impact assessment (Section 4);
 A review of the potential impacts from the proposed decommissioning activities and justification for the
assessments that support this EA (Section 5);
 Assessment of key issues (Section 6); and
 Conclusions (Section 7).

2 PROJECT SCOPE
2.1 Decision Making Context
BEIS (2018 and 2020) Guidance states that subsea installations (e.g. drilling templates, wellheads and their
protective structures, production manifolds and risers) must, where practicable, be completely removed for
reuse, recycling or final disposal on land. The Guidance states that any piles used to secure such installations
in place should be severed below the natural seabed level at such a depth to ensure that any remains are
unlikely to become uncovered. operators should aim to achieve a cut depth of 3m below the natural seabed
level, however consideration will be given to the prevailing seabed conditions and currents and this should be
detailed in the decommissioning programme and discussed with the relevant decommissioning team. The
Guidance also states that mattresses and grout bags installed to protect pipelines should be removed for
disposal onshore if their condition allows. If the condition of the mattresses or grout bags is such that they
cannot be removed safely or efficiently, any proposal to leave them in place must be discussed with the
Regulator.
With regards to pipelines (including flowlines and umbilicals), these should be considered on a case-by-case
basis. The guidance provides general advice regarding removal for two categories of pipelines:
 For small diameter pipelines (including flexible flowlines and umbilicals) which are neither trenched nor
buried, the guidance states that they should normally be entirely removed; and
 For pipelines covered with rock protection, the guidance states that these are expected to remain in place
unless there are special circumstances warranting removal.
The Guidance also highlights instances where pipelines could be decommissioned in situ. For example,
pipelines that are adequately buried or trenched or which are expected to self-bury could be considered as
candidates for in situ decommissioning. Where an Operator is considering decommissioning pipelines in situ,
the decision-making process must be informed by CA of the feasible decommissioning options. The CA takes
account of safety, environmental, technical, societal and economic factors to arrive at a preferred
decommissioning solution.
The following sections outline the decision making and CA process and detail the resultant emerging options
for the decommissioning of all of the infrastructure and pipelines within the Banff and Kyle Fields.
2.2 Alternatives to Decommissioning

Options to re-use the Banff and Kyle Field infrastructure in situ for future hydrocarbon developments have
been considered, but to date none have yielded a viable commercial opportunity. Reasons for this include the
absence of remaining hydrocarbon reserves in the vicinity of the infrastructure, and the limited remaining
design life and unsuitable material composition of the Banff and Kyle Field infrastructure. It is considered
unlikely that any opportunity to re-use the Field infrastructure will be feasible and, as such, there is no reason
to delay decommissioning of the infrastructure in a way that is safe and environmentally and socioeconomically
acceptable.
2.3 Comparative Assessment

All of the Banff and Kyle Field subsea infrastructure was assessed for decommissioning against the Guidance
Notes: Decommissioning of Offshore Oil and Gas Installations and Pipelines (BEIS, 2018). The recommended
CA process was applied. In accordance with normal practice for the Scoping phase of the CA, equipment was
organised into groups of items with similar characteristics, facilitating greater efficiency in processing the latter
phases of the CA. The guidance identifies certain equipment which must be fully removed and some categories
of pipelines which may be left decommissioned in situ subject to CA. Once the equipment groups designated
for full removal were identified the remaining groups were assessed further.
All possible decommissioning options for the remaining groups were coarsely screened against the primary
criteria as specified within the BEIS (2018) Guidance: Safety; Environment; Technical; Societal; and Economic.
The options were scored against each criterion either green, amber or red, pertaining to attractive, acceptable
or unattractive respectively. This process eliminated the least favourable options from each equipment group
in preparation for detailed evaluation of the remaining options. Those remaining options were then investigated

in detail to develop quantitative and qualitative data for each option pertaining to the primary criteria and sub-
criteria (e.g. safety data; environmental impact data; technical considerations; societal impacts; and costs).
Once this data had been prepared in the form of published studies, a detailed evaluation was conducted to
determine the final recommended decommissioning option for each item of equipment. This was facilitated by
comparing the data for each sub-criterion across the options using a Multi Criteria Decision Analysis (MCDA)
tool which employs pairwise comparisons of quantitative and qualitative data to produce a relative score for
each sub-criterion that can be summed to produce an overall relative score for each option, enabling
identification of the emerging recommendation for the group.
The CA groups which were considered for decommissioning are outlined in Table 2-1 and further details are
provided in the accompanying Banff and Kyle CA Report. All of the infrastructure groups considered prior to
scoping are included in Table 2-1, which also indicates whether the infrastructure was scoped in or out of CA.
Where only one option was identified for decommissioning the group was scoped out of CA. The selected
options are in bold and are covered in greater detail in Section 2.5 of this EA. Only Groups 1, 2, 4 and 8 were
carried through the CA process as all other groups were identified for full removal.
Table 2-1 CA Decommissioning Options Considered
CA Group Subsea Infrastructure Scoping Decommissioning Options Considered

No. Description Decision (selected option in bold)
and Buried Option 4a: Rock Placem ent over Ends /
Exposures
1 Option 4c: Remove Exposures
Hazards
Flexibles / Umbilicals Scoped in Option 2b: Reverse Reel w ithout De-Burial

Trenched and Buried Option 4a: Rock Placem ent over Ends /
2 Exposures
Hazards
Flexibles / Umbilicals, Scoped out Full Rem oval

3 Surface Laid
and Rock Covered Option 4a: Rock Placem ent over Ends /
4 Exposures
Hazards
5 Spools and Jumpers Scoped out Full Rem oval
Subsea Installations Scoped out Full Rem oval

6
(Structures)
Protection (Mattresses and Scoped out Full Rem oval

7
Grout Bags)
STL piles Scoped in Option 2c: Reverse Installation w ith De-Burial

Option 3a: Rock Cover Exposed Piles and Chains
8
Option 5: Leave in situ – Rem ove Piles to
Below the Seabed

2.4 Proposed Schedule

The precise timing of the decommissioning activities is not yet confirmed and will be subject to market
availability of cost-effective removal services and contractual agreements. As shown in Table 2 2, the potential
activity window for the Banff and Kyle subsea decommissioning activity is between 2022 and 2026.
Figure 2-1 Proposed Schedule of Banff and Kyle Decommissioning Activ ities
2.5 Decommissioning Activities
2.5.1 Groups 1, 2 and 4

The pipelines within the Banff and Kyle Fields have already been cut and cleaned and have been left open-
ended filled with seawater. As per the emerging CA options for Group 1, Group 2 and Group 4 (as defined in
Table 2-1 above), these groups will be decommissioned in situ with rock placement over areas of exposure
and at exposed ends. Rock will be placed along the transition zones wherein the pipelines start as surface
laid before entering a trench. The transition zones are approximately 50 m long within the Banff Field and 20
m long in the Kyle Field. The length of rock will therefore be along a 50 m section of pipeline transition at Banff
and 20 m at Kyle. Rock will be placed out to a width of ~10 m which results in a maximum anticipated area of
200 m2 to 500 m2 covered by rock at each pipeline end. A rock placement vessel will carry out the remediation
activities.
In addition, any areas of exposure will also be remediated using rock as appropriate. There are 23 exposures
(totalling a length of 345 m) across the Group 1 pipelines. The Group 2 and Group 4 pipelines are all stably
buried. Table 2-2 presents a description of the pipelines considered within each group. A full inventory of
items to be decommissioned as part of the DP is available in Appendix A.
Table 2-2 Group 1, 2 and 4 Pipelines in the Banff and Kyle Fields
Group PL number Description Length (m)
Trenched & Buried, P2 10" Banff Oil

PL1546 1,546
Production
Trenched & Buried, P1 10" Banff Oil
PL1547 1,546
Production
Trenched & Buried, 10" Water Injection
1 PL1548 1,715
(Disconnected)
PL2388 Trenched & Buried, 4” Gas Lift Pipeline 3,289
PL1550 Trenched & Buried, 12" Banff Oil Export 1,248
12” Curlew Production Pipeline, Trenched
PL1798 17,383
TBC

Group PL number Description Length (m)
Trenched & Rock Covered, Kyle 8"

PL1660 12,023
Production Pipeline
PL1797 8” Production Pipeline, Trenched & Buried 3,291
Trenched & Buried TBC, 6" Banff Gas Lift /
PL2052 1800
Injection
PL1552 1 & 2, Trenched & Buried, Banff Chemical Injection
1,990
PL1553, PL1554.1 –7 System, Controls and Chemical Umbilical
2 Trenched & Buried, Kyle ECI Umbilical

PLU3117 12, 292
(Electrical / Chemical)
PL1800 Curlew Control Umbilical 17,550
PL1799.1 – 8 Trenched & Buried, Main Kyle Umbilical 3,607
PL1661.1 –22 Trenched & Rock Covered, EHC Umbilical 11,926
Trenched & Rock Covered, 4" Gas Lift
PL2387 10,252
Pipeline
4
Trenched & Rock Covered, 6" Banff Gas
PL1549 6,268
Export
2.5.2 Group 3
This group contains two umbilicals which are both surface laid into shallow trenches. These umbilicals will be
fully removed using a winch on a Construction Support Vessel (CSV) and will be cut on deck where required.
The details of the umbilicals are provided in Table 2-3. A full project inventory is available in Appendix A.
Table 2-3 Group 3 Pipelines in the Banff and Kyle Field
Group PL number Description External Length (m)

Diameter (mm)
PLU4522 Power Umbilical 83 1,600

3
PLU3106 Banff gas export SSIV umbilical 83 536
2.5.3 Structures
Table 2-4 outlines all the infrastructure within the Banff and Kyle Fields which is to be fully removed during
decommissioning. For full infrastructure details and dimensions see Appendix A.5. Prior to recovery, a Dive
Support Vessel (DSV) may be required to prepare some of the structures for rigging and cutting connections.
The subsea structures will be recovered by CSV before being returned to shore.
Well structures (including nine Xmas Trees and five abandoned guide bases) are presented here as part of
the Banff and Kyle subsea inventory, however, as they are associated with the Banff and Kyle wells, their
removal and the associated impact is out of scope of the EA and will be addressed via permitting prior to well
decommissioning.

Table 2-4 Infrastructure Details for the Banff and Kyle Decommissioning
Infrastructure Description Proposed

Strategy
Banff Gas Lift SSIV Structure 8.7 m x 8.3 m x 3.4 m
SSIV
Pipelines1 Banff Gas Export SSIV Structure 10 m x 5.5 m x 3.9 m Full removal
Structures
Kyle Subsea Isolation Valve (SSIV) Structure 6 m x 7.5 m x 3.2 m
Banff to Kyle North Umbilical Wet Splice 3 m x 1.2 m x 0.8 m

Pipeline Wet
Full removal
Structures Splice Kyle North to Kyle South Umbilical Wet
2.6 m x 1.2 m x 0.6 m
Splice
Subsea Distribution Unit (SDU) Structure 9 m x 8 m x 1.9 m
Gas Lift / Choke Manifold 13 m x 11 m x 3.7 m
North Drill Centre Valve Structure 10 m x 8 m x 2.4 m
Kyle Production Riser Base 8 m x 8 m x 3.2 m
Kyle Umbilical Riser Base 8 m x 8 m x 3.2 m

Kyle Disconnected SDU / Subsea Accumulator
7.6 m x 6.8 m x 1.8 m
North Module (SAM) Structure
Umbilical Tee c/w Protective Cover 6.2 m x 3 m x 1.3 m
Abandoned Guide Base 2.8 m x 2.8 m x 3 m
Xmas Tree w ith Guide Base Well K14 5.3 m x 5.3 m x 5.2 m
Abandoned Umbilical Tee Connector 6.2 m x 4.3 m x 1.3 m
12" Tee Structure 11.8 m x 8.8 m x 2.2 m
Subsea Gas Lift / Choke Manifold 13 m x 11 m x 3.7 m

Full removal
Structures South Drill Centre Valve Structure 10 m x 8 m x 2.4 m
Kyle
South Curlew Umbilical DUTU 3 m x 1.3 m x 1.2 m
Banff Gas Lift / Injection Manifold 18 m x 14 m x 4.8 m
Banff Production Manifold 18 m x 16 m x 5.2 m
Gas Lift / Choke Manifold 13 m x 11 m x 3.7 m

Banff Dynamic Umbilical Termination Unit
7.5 m x 5.5 m x 2.9 m
(DUTU) Structure
Banff P1 Production Riser Base 8.7 m x 4.5 m x 4.3 m
P2 Production Riser Base 8.7 m x 4.5 m x 4.3 m
Gas Lift / Injection Riser Base 8.65 m x 4.5 m x 4.3 m

Oil Export Tether Base 7 m x 7 m x 2.9 m
Oil Export STL Tether Base 4 m x 3 m x 1.4 m
1
Where pipelines remaining in situ have a direct link to infrastructure (and it is not feasible to remove a spool
or jumper), they will be cut at minimal length to enable the removal of this infrastructure. The environmental
impact of this activity is accounted for here within the footprint of the associated infrastructure.

Infrastructure Description Proposed

Strategy
Banff Suction Base (SAL Anchor Base) 9 m x 9 m x 16.7
Pipeline End Manifold (PLEM) Tee 3.1 m x 3 m x 1.7 m
Banff Umbilical Tether Base 7 m x 7 m x 2.9 m
Gas Export Tether Base 7 m x 7 m x 2.9 m
Banff Umbilical Tether Base Anode Skid A 2.5 m x 1.5 m x 0.5 m
Banff Umbilical Tether Base Anode Skid B 2.5 m x 1.5 m x 0.5 m
Gas Export Tether Base Anode Skid A 2.5 m x 1.5 m x 0.5 m

Gas Export Tether Base Anode Skid B 2.5 m x 1.5 m x 0.5 m
Gas Export SSIV Anode Skid 2.1 m x 1.5 m x 0.5 m
Riser Base Structure Anode Skid A 2.5 m x 1.5 m x 0.5 m
Riser Base Structure Anode Skid B 2.5 m x 1.5 m x 0.5 m
PLEM Tee Anode Skid 0.75 m x 0.5 m x 0.2 m

Abandoned Guide Base 9.4 m x 9.4 m x 3.1 m
Abandoned Guide Base 2.8 m x 2.8 m x 3 m
Abandoned Guide Base 3 m x 3 m x 3.4 m

Abandoned Guide Base 3 m x 3 m x 3.4 m
Xmas Tree w ith Guide Base Well B1 5.3 m x 5.3 m x 5.2 m
2.5.4 Group 8
Group 8 is comprised of eight STL piles which remain as part of the historic location of the Apollo Spirit FSO.
All eight are located in the north of the Banff Field. Amongst the eight piles, there are three different sizes.
The pile dimensions are presented in Table 2-5 below and further details are available in Appendix A.6. The
CA outcome determined removal with prior de-burial to be the best method. The remediation will involve
internal dredging of the top of the pile in order to insert a cutting tool which will cut and recover the top of the
pile, such that the remaining section of pile does not protrude above the seabed or pose a risk of doing so over
time, based on seabed movement.
The piles will be recovered by winch to a CSV before being returned to shore. Once the pile structure has been
removed, the area will be remediated as appropriate and under discussion with OPRED. The most likely
scenario is that the dredged sediment will be backfilled into the remaining holes, however, rock placement
within this footprint is assessed in this EA as a worst-case scenario.

Table 2-5 Group 8 Structures in the Banff Field
Group Structure Number Dimensions (m)
4 30 x 1.83
8 STL pile 3 24 x 1.83
1 28 x 1.83
2.5.5 Spools, Jumpers and Other Pipeline Sections

Spools and jumpers and some surface laid sections of pipelines were considered in the CA process but early
on, and in line with Regulatory guidance (BEIS, 2018), were determined for full removal. The spools, jumpers
and pipeline sections will be prepared for recovery by cutting connections and they will be recovered by winch
to a CSV before being returned to shore. A full inventory of these pipeline components is included in Appendix
A.7.
2.5.6 Further Remediation

In addition to the remediation which will occur in association with the pipelines and potential remediation at the
STL pile dredging location, there are some depressions remaining in the Banff Field which are remnants of the
presence of the Petrojarl Banff FPSO. There are ten trenches which are associated with the former location
of the FPSO mooring lines where they interacted with the seabed at the touchdown points. These touchdown
trenches are at their deepest closest to the former location of the FPSO and have very steep (almost vertical)
sides. Additionally, there are a corresponding ten depressions associated with the former FPSO anchor
locations. The dimensions of these touchdown trenches and depressions are presented in Table 2-6 and
Table 2-7 respectively. In both tables, the width and depth given are the maximum approximate values
observed.

Table 2-6 FPSO Mooring Line Trenches
Trench Start Position Trench End Position

Mooring Length Width (m) Depth (m)
Line Easting Northing Easting Northing (m)
(m) (m) (m) (m)
1 396428 6319122 396452 6319186 68 4 4
2 396440 6319087 396479 6319155 78 4 4
3 396510 6318956 396647 6318948 137 >8 8
4 396509 6318918 396678 6318872 175 >8 7
5 396385 6318841 396410 6318659 184 >8 9
6 396370 6318811 396378 6318641 170 >8 9
7 396233 6318881 396132 6318811 123 >8 7
8 396245 6318909 396111 6318853 173 >8 8
9 396275 6319043 396139 6319155 176 >8 8
10 396269 6319078 396182 6319189 141 >8 6
Table 2-7 FPSO Anchor Depressions
Depression Start Position Depression End Position

Mooring Length Width Depth
Line Easting Northing (m) (m)2 (m)
Easting (m) Northing (m)
(m) (m)
1 397215 6321121 397232 6321146 30 10 1
2 397550 6320950 397567 6320973 29 10 2
3 398691 6318798 398711 6318795 20 10 2
4 398624 6318391 398640 6318392 25 10 2
5 396719 6316711 396736 6316633 80 10 4
6 396393 6316635 396389 6316595 40 10 1
7 394363 6317715 394343 6317698 26 10 2
8 394188 6318078 394118 6318045 77 10 2
9 394570 6320470 394496 6320430 91 10 2
10 394891 6320722 394869 6320762 46 10 2
The trenches and depressions are shown in the context of the wider Banff Field in Figure 2-2. The anchor
depressions associated with mooring lines 1, 2, 3, 4, 9 and 10 are all located within the NCMPA. The mooring
trenches associated with mooring lines 1, 2 and 3 are all located fully or partly within the NCMPA. CNRI are
conducting a study of these features to determine the most appropriate method of targeted remediation and
will monitor the depressions in the interim to assess change over time. The results of the study will be relayed
to OPRED and a discussion will be initiated to determine the most appropriate course of action. The method
of remediation is therefore yet to be determined, with the worst-case assumption involving the placement of
rock to fill the dimensions of the trenches. It is possible that rock infill would not be all the way up to seabed
level; this would allow for some natural backfilling by sediment to cover the rock over time. Any future
remediation activities relating to the mooring trenches and anchor depressions in the Banff Field will also be
covered by the applicable permitting once confirmed with OPRED.
Estimated tonnages of rock are provided in Table 2-8 which are likely to be required to remediate each of the
FPSO mooring line trenches and anchor depressions (should remediation using rock be the chosen method).
All estimates include a 10% contingency to account for inaccuracies within the dimensions of the scar
dimensional estimates. An area of rock placement has also been calculated in Table 2-8 using the dimensions
of the trenches and depressions, as presented in Table 2-6 and Table 2-7 above.
2
The width of the scars is uncertain from the ROV footage but is unlikely to significantly exceed the width of
the anchors themselves. A typical estimate of between 8 m – 10 m width is considered sufficient. In the interest
of presenting a worst-case scenario, the upper end of this assumption (i.e. 10 m) has been presented here.
This width is also used in the calculation of areas in Table 2-8.

Table 2-8 Rock Placement Infill and Area Estimates
Rock Placement Estimate (Te) Rock Placement Estimate (m 2)

Mooring Line
Mooring Line Anchor Mooring Line Anchor
Trenches Depressions Trenches Depressions
1 987 218 272 300
2 1133 421 312 290
3 7957 290 1096 200
4 8894 363 1400 250
5 12023 2323 1472 800
6 11108 290 1360 400
7 6251 378 984 260
8 10048 1118 1384 770
9 10222 1321 1408 910
10 6142 668 1128 460
Subtotal 74763 7391 10816 4640
Total 82154 15456

Anchor
Figure 2-2 Mooring trenches associated w ith the former location of the Petroj arl Banff FPSO

2.5.7 Protection (Mattresses and Grout Bags)

All subsea protection and stabilisation infrastructure (i.e. concrete mattresses and grout bags) will be fully
recovered, unless associated with third party crossings / infrastructure. There are an estimated 1,550
mattresses in the Banff and Kyle Fields, split across two different sizes; Table 2-9 provides a summary of
concrete mattresses associated with the Banff and Kyle Fields. Of these, the majority (1,440) are associated
with the pipelines within the Fields. The remaining 110 are associated with the subsea installations.
The number of grout bags within the Banff and Kyle Fields is also shown in Table 2-9. The number of grout
bags presented is an estimate. Standard grout bag dimensions have been assumed.
Prior to their retrieval mattresses will be stacked to allow for more efficient removal. A CSV will be used to
retrieve the stabilisation materials and return them to shore. Grout bags will be removed using an Orange Peel
Grab.
While the intention is to fully remove all protection / stabilisation materials, with the exception of any mattresses
associated with crossings, should stabilisation features not have sufficient integrity to allow for full removal
CNRI shall engage with the regulator regarding alternative options.
Table 2-9 Protection Features w ithin the Banff and Kyle Fields
Stabilisation Feature Dimensions (m) Total Number
Concrete Mattresses 6 x 3 x 0.15 1,340

Concrete Mattresses 6 x 3 x 0.3 210
Grout Bags (25 kg bags) 0.6 x 0.3 15,500
2.6 Summary of Material Inventory

The sections below summarise the inventory of materials associated with the subsea infrastructure to be
decommissioned. Comprehensive information about the materials present within the Banff and Kyle Fields
are provided.
Table 2-10 and Figure 2-3 summarise the total weight of each component’s materials for the Banff and Kyle
Field subsea installations.
Table 2-10 Material Inv entory Associated with the Banff and Kyle Installations
Items Description Weight (tonnes)

Steel (all grades) 2,944.44
Metals
Non- Ferrous (Copper, Aluminium) 9.01
Concrete Aggregates (mattresses and grout bags) 774.25
Plastic Rubbers, polymers 0
Residual Fluids (hydrocarbons, chemicals) Trace
Hazardous
NORM scale To be determined
Other Glass filament, Silica 0
Total for the Banff and Kyle Fields 3,727.7

Figure 2-3 Pie chart of the estimated inv entory of subsea installations (including associated stabilisation materials)
Table 2-11 and Figure 2-4 summarise the total weight of each component’s materials for the Banff and Kyle
Field pipelines.
Table 2-11 Material Inv entory Associated with the Banff and Kyle Pipelines
Items Description Weight (tonnes)

Steel (all grades) 3,604.13
Metals
Non- Ferrous (Copper, Aluminium) 370.37
Concrete Aggregates (mattresses and grout bags) 10,496.25
Plastic Rubbers, polymers 15.43
Residual Fluids (hydrocarbons, chemicals) Trace
Hazardous
NORM scale To be determined
Other Glass filament, Silica Trace
Total for Banff and Kyle Field 14,486.18
Figure 2-4 Pie chart of the estimated inv entory of pipelines (including associated stabilisation materials)

2.7 Post-Decommissioning Activities
2.7.1 Clear Seabed Verification

Following the decommissioning of the Banff and Kyle Field infrastructure, it will be necessary to identify any
potential snagging hazards associated with any changes to the seabed and remediate these. A clear seabed
will be validated by an independent verification survey of all of the installation sites and pipeline corridors. The
aim of these clean seabed verification actions is to ensure the seabed is left in a safe condition for future fishing
effort, in line with the current Decommissioning Guidance (BEIS, 2018).
The survey methods will be discussed and finalised with OPRED prior to survey commencement to ensure the
survey meets the requirements for clear seabed verification. Non-intrusive verification techniques will be
considered in the first instance. These may include techniques which do not make contact with the seabed,
such as Side Scan Sonar (SSS) and Remotely Operated Vehicle (ROV) surveys.
Where these are deemed inconclusive by the Scottish Fishermen’s Federation (SFF), or where there is
evidence of snagging hazards requiring intervention (e.g. any spans, berms, dropped objects, etc.), targeted
overtrawling may be undertaken to ensure no residual risk of snagging remains post-decommissioning. Should
overtrawling be required, it will be conducted by fishing vessel(s) using trawl gear that is appropriate for the
area. Post-decommissioning surveys shall be conducted, and any debris identified shall be recovered and
recycled / disposed of accordingly.
2.8 Waste Management

Waste will be dealt with in accordance with the Waste Framework Directive. The re-use of any infrastructure,
spools and jumpers – or parts thereof, is first in the order of preferred decommissioning options. Options for
re-use of an infrastructure, spools and jumpers – or parts thereof are currently under investigation. Waste
generated during decommissioning will be segregated by type and periodically transported to shore in an
auditable manner through licensed waste contractors.
Article 4 of the EU Waste Framework Directive (Directive 2008/98/EC) sets out the five steps to manage waste
ranked according to environmental impact (also knowns as the waste hierarchy). In line with the waste
hierarchy, the re-use of an installation (or parts thereof) is first in the order of preferred decommissioning
options. CNRI will follow the principles of the waste hierarchy (Figure 2-5) in order to minimise waste
production resulting from any removal of subsea infrastructure, spools and jumpers (including stabilisation
materials).
Figure 2-5 Waste hierarchy

Recovered infrastructure will be returned to shore and transferred to a suitably licenced decommissioning
facility and it is expected that the recovered infrastructure will be cleaned before largely recycled.
Appropriately licensed waste management facilities will be identified through a selection process that will
ensure that the chosen facilities demonstrate a proven record of waste stream management throughout the
deconstruction process, the ability to deliver innovative reuse/ recycling opt ions, and ensure the aims of the
waste hierarchy are achieved.
Geographic locations of potential disposal yard may require the consideration of Trans Frontier Shipment of
Waste (TFSW), including hazardous materials. Early engagement with the relevant wast e regulatory
authorities will ensure that any issues with TFSW are addressed before the shipment of any waste.
CNRI will engage with other companies and industries to identify potential reuse opportunities. Both
companies recognise that such opportunities are best achieved through the tendering and selection of a waste
management contractor with expert knowledge and experience in this area.
2.9 Environmental Management Approach

CNRI each have established and independently verified Environmental Management Syst ems (EMS) both of
which operate in accordance with the requirements of ISO14001:2015. The scopes of the CNRI’s EMS’ are
defined to include all activities, onshore and offshore, in relation to the exploration for and production of
hydrocarbons in defined license areas of the UK sector of the North Sea. This scope encompasses the
proposed Banff and Kyle Filed decommissioning. Both EMS’ meets the requirements of OSPAR
Recommendation 2003/5 which promotes the use and implementation of the Environmental Management
System (EMS) by the offshore industry. The EMS is an integral part of both CNRI’s Safety, Health and
Environmental Management Systems which describes the means of compliance with SHE legislation and
industry standards, and manages SHE risks in their respective businesses. Relevant to the EA, and to all of
CNRI’s activities, is the commitment to managing all environmental impacts associated with their activities.
Continuous improvement in environmental performance is sought through effective project planning and
implementation, emissions reduction, waste minimisation and waste management; this mindset has fed into
the development of the mitigation measures developed for the Project; these include both industry -standard
and project specific measures. Signed copies of CNRI’s Health and Safety Policy and Environmental
Management Policy are presented in Appendix B.

3 ENVIRONMENTAL AND SOCIETAL BASELINE

3.1 Background
Information is provided here on the environmental baseline characteristics around the Banff and Kyle Fields
to help inform an assessment of the features that may be affected by the proposed decommissioning
operations or may have a bearing on the nature and extent of relevant impacts. The potential interactions
between project activities and environmental receptors are detailed and assessed in Section 6. As the
activities associated with the DP will form a presence over several years, environmental features and any
relevant changes in their characteristics and sensitivities are described across the entire year.
The project scope (Section 2) and initial screening (Section 5) suggests that the majority of potentially
significant environmental impacts would be felt within close proximity to the proposed development location.
Therefore, environmental sensitivities are described on a local scale, with broader scale data only used where
appropriate to certain ecological characteristics, such as broad scale habitat classification. Certain activities
or events could potentially have more spatially extensive environmental impacts. In these instances, those
environmental sensitivities that may be affected are described on a greater spatial scale.
In this regard, Section 3.3 provides an overview of all the environmental and societal sensitivities in the area.
Details have been provided on the receptors most likely to be impacted by the proposed activities in the
sections below. This baseline characterisation describes the current conditions of the receiving environment
comprising the Banff and Kyle Fields and is considered sufficient to enable effective evaluation of the potential
environmental interactions from proposed decommissioning activities.
3.2 Summary of Environmental Surveys

Pre-decommissioning surveys for habitat assessment and environmental baseline data collection were
conducted in the Banff and Kyle Fields in 2020 (Fugro, 2020a, 2020b, 2020c). These surveys gathered seabed
samples and imagery to acquire an understanding of the range of seabed habitats and communities present,
including the potential presence of any species or habitats of conservation concern prior to the commencement
of decommissioning activities. An outline of these surveys is provided in the proceeding sections.
3.2.1 Banff Habitat Assessment Report (2020)

Twelve stations were sampled within the Banff Field during this survey. The stations were arranged in a
cruciform manner centred around the Banff manifold. The stations were aligned with the predominant tidal
current direction. Photographic data was collected along 20 m transects positioned at each sampling station.
The sediment samples were taken at depths ranging from 89 to 96 m (Fugro, 2020a). This survey aimed to
assess the possible presence of marine Annex I habitats in the Banff Field, as well as PMFs, OSPAR
threatened and / or declining species and habitats, and Priority Species and Habitats (UKBAP).
3.2.2 Kyle Habitat Assessment Report (2020)

Twenty-four stations were sampled across the Kyle survey area. Twelve sites were arranged in a cruciform
pattern around both the Kyle North and Kyle South drill centres. A total of three survey transects were
undertaken; one at Kyle North and a further two at Kyle South. The maximum sample depth at Kyle North was
96 m, at Kyle South the maximum depth was 92 m (Fugro, 2020b). This survey, as above, aimed to assess
the possible presence of protected marine habitats within the Kyle Field.
3.2.3 Environmental Pre-Decommissioning Report: Banff and Kyle (2020)

The Banff and Kyle Habitat Assessment Reports were conducted as part of, and contributed to, the overall
Environmental Pre-Decommissioning Report (Fugro, 2020c) therefore the survey strategy reflects that which
is described in Sections 3.2.1 and 3.2.2 above. In addition to benthic faunal identification, this survey
investigated the sediment chemical findings across the Fields and provides information regarding the presence
of any historical drill cuttings.

Figure 3-1 Surv ey cov erage w ithin the Banff and Kyle Fields
3.3 Baseline Summary

The baseline environmental and societal receptors within the project area are summarised in Table 3-1. For
most receptors, the information provided in the table is considered sufficient to inform the environmental
assessment of potential impacts within this EA. Receptors identified during the Environmental Identification
(ENVID; the process of which is described in Section 4) and consultation meetings as of specific interest to
stakeholders included the seabed and benthic environment, conservation sites and species, and commercial
fisheries. These sensitive receptors are discussed in more detail in the subsequent sections (within Section
3.4).

Table 3-1 Summary of Env ironmental and Societal Receptors
Environmental Description
Receptor
Conservation Interests (will be addressed in greater depth in Section 3.4.1)
OSPAR (2008) List of Threatened and / or Declining Species and Habitats
Ocean quahog No adult ocean quahog (A. islandica, >1 cm) were recovered within either of the Banff or
Kyle surveyed areas. Furthermore, the presence of ocean quahog siphons was not
observed in any of the survey footage (Fugro, 2020a, 2020b). However, the species and
its associated habitat is one of the reasons for the designation of the East of Gannet and
Montrose Fields NCMPA, within which the Banff Field is partially located.
Seapens and This habitat was present within both the Banff and Kyle Field survey areas. According to
burrowing the SACFOR classification, the seapen P. phosphorea ranged from ‘occasional’ to
megafauna ‘common’ during the Banff survey. V. mirabilis was ‘frequent’ at one station and ‘absent’
communities at all others. Faunal burrows between 3-15 cm were either ‘frequent’ or ‘common’ at the
four sites where they were present (Fugro, 2020a).
Faunal burrows sized 3-15 cm were considered either ‘common’ or ‘frequent’ at all Kyle
North sites. At Kyle South the SACFOR classification of faunal burrows was ‘common’ at
all but one site which was considered ‘abundant’. Burrows >15 cm were ‘absent’ at all
stations and ‘frequent’ along both visual transects (Fugro, 2020b).
Both ‘Burrowed mud’ and ‘Seapens and burrowing megafauna in circalittoral fine mud’ are
also considered PMFs.
Other conservation interests
Annex I No Annex I Habitats were identified in any of the site-specific surveys.

habitats
Conservation Sites (will be addressed in greater depth in Section 3.4.2)
SAC The nearest SAC is the Scanner Pockmark SAC (~140 km north of Banff and ~151 km
from Kyle). It is designated for the presence of Annex I feature ‘Submarine structures
made by leaking gases’.
NCMPA The Banff Field is partly located within the East of Gannet and Montrose Fields NCMPA.
The site is ~10 km due north of the Kyle Field. The site is designated for the protection of
ocean quahog aggregations and deep-sea muds.
MCZ The Fulmar MCZ is located ~50 km southeast of the Kyle Field (and ~60 km from the Banff
Field). The site is designated for Subtidal mixed sediments, Subtidal sand, Subtidal mud
and ocean quahog aggregations.
Conservation Species (will be addressed in greater depth in Section 3.4)
Coastal and Offshore Annex II species most likely to be present in the project area
Pinnipeds – About 38% of the world population of grey seal Halichoerus grypus occur in the UK, with
grey and 88% of the UK population breeding in Scotland. Most of the grey seal population will be
harbour seals on land from October to December during the breeding season, and in February and March
during the annual moult, therefore densities at sea are likely to be lower at these times of
the year (DECC, 2016). The density of grey seals within the Banff and Kyle fields is 0-1
individuals per 25km 2 (Russell et al., 2017).
Harbour seals Phoca vitulina are also concentrated in Scotland, where 79% of the UK
population live and / or breed (Jones et al., 2013). Harbour seals generally haul out on

Receptor
tidally exposed areas of rock, sandbanks or mud. Pupping season is between June and
July, and the moult occurs in August and September, therefore from June to September
harbour seals are on shore more often than at other times of the year (DECC, 2016). The
predicted density of harbour seals within the Project area is very low, 0-1 animal per 25km2
(Russell et al., 2017).
European Protected Species (EPS) most likely to be present in the project area
Harbour Harbour porpoise (Phocoena phocoena) are amongst the most frequently observed
porpoise cetacean species in the North Sea, seen throughout the year (Reid et al., 2003). They
have been spotted at the Project location in the months of May, July, August, September.
The predicted density of harbour porpoises in the vicinity of the Project area is moderate-
high compared to the rest of the UK waters, with an estimate of around 0.59 animals per
km2 (Hammond et al., 2017). They are also listed as a UK Biodiversity Action Plan (BAP)
species.
Atlantic white- Atlantic white-sided dolphins (Lagenorhynchus acutus) live mainly in cool waters (7-12°C),
sided dolphin particularly seaward or along the edges of the continental shelf in depths of 100-500 m
(Reid et al., 2003). However, the species can also be numerous in much deeper, oceanic
waters. They are found in deep waters around the north of Scotland throughout the year
but enter the North Sea mainly in the summer (Reid et al., 2003; Hammond et al., 2017).
Within the Project area, white-sided dolphins have been observed in July. Their density is
estimated to be 0.01 animals per km 2, which is high in comparison with other areas of the
UK (Hammond et al., 2017). They are also listed as a UK BAP species.
Short-beaked Short-beaked common dolphins (Delphinus delphis) favour deep water habitats out of all
common the common dolphin species found globally. In north-west European waters they are
dolphin usually observed in groups of six to ten, though large schools (>100) have been observed
frequently. They have been observed in the Project vicinity in August (Reid et al., 2003).
They are so infrequently observed in the region of the Project that estimates of their
abundance have not been made. They are also listed as a UK BAP species.
Minke whale Minke whales (Balaenoptera acutorostrata) occur in water depths of 200 m or less
throughout the northern North Sea and CNS. They are usually sighted in pairs or in
solitude; however, groups of up to 15 individuals can be sighted feeding. It appears that
animals return to the same seasonal feeding grounds (Reid et al., 2003). They have been
observed in May and July in the Project area. Their density is predicted to be 0.04
animals/km2 which is the highest across all areas surveyed (Hammond et al., 2017). They
are also listed as a UK BAP species.
White-beaked White-beaked dolphins (Lagenorhynchus albirostris) are found mostly in continental shelf
dolphin waters with depths between 50 m and 100 m, and rarely out to the 200 m isobath (Reid et
al., 2003). White-beaked dolphins are usually found in groups of around 10 individuals,
although large groups of up to 500 animals have been seen. They may be found in the
Project area throughout much of the year with peaks in summer; they have been observed
in February, July, August, September, October, and November. The species are roughly
estimated to have a density of 0.24 animals/km2 near the Project area (Hammond et al.,
2017). They are also listed as a UK BAP species.
Benthic Environment (will be addressed in greater depth in Section 3.4.1)
Seabed The Banff Field is located partly within A5.27 ‘Deep circalittoral sand’, and also within an
composition area of A5.37 ‘Deep circalittoral mud’. The Kyle Field is almost exclusively located within
A5.37 ‘Deep circalittoral mud’. Directly to the south of the Banff Field is a small patch of
A5.15 ‘Deep circalittoral coarse sediment’ (EMODnet, 2019). Side-scan sonar (SSS) data
revealed regions of seabed which had higher sonar reflectivity corresponded with regions
of A5.44 ‘Circalittoral mixed sediment’ in the Banff Field (Fugro, 2020a).

Receptor
Though no cuttings piles are evident in the project area, sediment contamination levels
indicate the presence of historic piles. Drilling fluid inputs were evident at some of the
locations within the Banff and Kyle Fields (Fugro, 2020c).
Benthic fauna Benthic fauna was much the same between the Banff and Kyle Fields. The dominant taxa
observed within both the sandy and mixed substrate at the Banff Field, were sea pens
(Pennatula phosphorea), hermit crabs (Paguridae) and anemones (Actiniaria including
Hormathiidae and Epizoanthus papillosus) (Fugro, 2020a). Sea urchins (Gracilechinus
acutus) were additionally amongst the dominant species within the Kyle Field (Fugro,
2020b). Bioturbation was evident across both survey areas (Fugro 2020a, 2020b).
Fish – spawning and nursery grounds

Spawning The project area is located within the high intensity spawning grounds of mackerel
grounds (Scomber scombrus) and Norway pout (Trisopterus esmarkii) as well as the spawning
grounds of cod (Gadus morhua), lemon sole (Microstomus kitt) and sandeel (Ammodytidae
sp.) (Coull et al., 1998; Ellis et al., 2012).
Nursery The following species have nursery grounds in the vicinity of the project area: anglerfish
grounds (Lophius piscatorius), blue whiting (Micromesistius poutassou), cod, European hake
(Merluccinus merluccinus), haddock (Melanogrammus aeglefinus), herring (Clupea
harengus), ling (Molva molva), mackerel, Norway pout, plaice (Pleuronectes platessa),
sandeel, spurdog (Squalus acanthias) and whiting (Merlangius merlangus) (Coull et al.,
1998; Ellis et al., 2012).
Fisheries sensitivity maps indicate that the probability of significant aggregations of
juveniles of these species in the project area is low (Ellis et al., 2012).
Probability of Aires et al. (2014) provides modelled spatial representations of the predicted distribution
juvenile fish of 0 age group fish. The modelling indicates the presence of juvenile fish (less than one
aggregations year old) for multiple species: anglerfish, blue whiting, European hake, haddock, herring,
mackerel, horse mackerel (Trachurus trachurus), Norway pout, plaice, sprat (Sprattus
sprattus), and whiting. Across the project area, the probability of juvenile fish aggregations
occurring is low for all species (<0.15).
Seabirds
According to the density maps provided in Kober et al. (2010), the following species could be found within
the project area: northern fulmar (Fulmarus glacialis), Manx shearwater (Puffinus puffinus), European storm-
petrel (Hydrobates pelagicus), northern gannet (Morus bassanus), Arctic skua (Stercorarius parasiticus),
great skua (Stercorarius sk ua), black-legged kittiwake (Rissa tridactyla), great black-backed gull (Larus
marinus), common gull (Larus canus), lesser blackbacked gull (Larus fuscus), herring gull (Larus argentatus),
Arctic tern (Sterna paradisaea), common guillemot (Uria aalge), razorbill (Alca torda), little auk (Alle alle),
Atlantic puffin (Fratercula arctica) and pomarine skua (Stercorarius pomarinus). Seabird Oil Sensitivity Index
(SOSI) identifies areas at sea where seabirds are likely to be most sensitive to surface pollution (Webb et al.,
2016). Seabird vulnerability in Blocks 22/27, 29/2 and 29/7 is low throughout the year with no data for
November. Block 29/11 experiences a Very High SOSI value in the months of September and October
(Webb et al., 2016). The risk of an oil spill from the proposed operations in the project area is considered
remote and therefore the overall risk to birds is considered negligible.

Receptor
Seabird Oil Sensitivity Index
Month Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
22/21 5 5* 5 5* 5* 5 5 5 5 5* N 5*
22/22 5 5 5 5* 5* 5 5 5 5 5* N 5*
22/23 5 5 5 5* 5* 5 5 5 5 5* N 5*
22/26 5 5* 5 5* 5* 5 5 5 5 5* N 5*
22/27 5 5* 5 5* 5* 5 5 5 5 5* N 5*
22/28 5 5 5 5* 5* 5 5 5 5 5* N 5*
29/1 5 5 5 5* 5* 5 5 5 5 5* N 5*
29/2 5 5 5 5* 5* 5 5 5 5 5* N 5*
29/3 5 5 5 5* 5* 5 5 5 5 5* N 5*
29/6 5 5 5 5* 5* 5 5 5 5 5* N 5*
29/7 5 5 5 5* 5* 5 5 5 5 5* N 5*
29/8 5 5 5 5* 5* 5 5 5 5 5* N 5*
29/11 5 5 5 5* 5* 5 5 5 2 2* N 5*
29/12 5 5 5 5* 5* 5 5 5 5 5* N 5*
29/13 5 5 5 5* 5* 5 5 5 5 5* N 5*
1 = Extremely high 2 = Very High 3 = High 4= 5 = Low N = No data
Medium
Key
*in light of coverage gaps, an indirect assessment of SOSI has been made
Commercial Fisheries (will be addressed in greater depth in Section 3.4.3)
The Banff and Kyle Fields lie in International Council for the Exploration of the Seas (ICES) Rectangles 42F1
and 43F1 (Scottish Government, 2020).
The waters comprising the Banff and Kyle are fished for a variety of species by both UK and foreign vessels.
ICES rectangle 42F1 has predominantly been targeted for shellfish in recent years, whilst the adjacent ICES
rectangle 43F1 experiences a much greater amount of demersal fishing. Shellfish species caught in ICES
rectangle 42F1 comprised >50% of the total landings live weight in 2019 and constituted over five times the
average live weight of shellfish landings in 43F1 (between 2015 and 2019; Scottish Government, 2020). The
total annual landings for the Banff and Kyle Area (ICES rectangles 42F1 and 43F1) were ≤1% of the total
landings within the UKCS for each of the five most recent fishing years (Scottish Government, 2020).
In 2019 fishing effort in ICES rectangle 42F1 was highest for January, March and November (45, 42 and 42
days respectively), together accounting for 51% of the total number of days fished. Overall effort was low for
42F1 (Scottish Government, 2020). Comparatively, fishing effort in ICES rectangle 43F1 is much lower. In
2019, effort was highest in January (only 6 days), accounting for 21% of the total number of days fished, with
the other disclosive months contributing for the remaining fishing effort (Scottish Government, 2020).
Trawls were the most utilised gear in rectangle 42F1 and 43F1. In total, trawls contributed 99% of the total
fishing effort in rectangle 42F1. In rectangle 43F1 approximately 86% of total fishing effort was from trawls
with the remainder being attributed to seine nets (Scottish Government, 2020).

Other Sea Users
Shipping The Banff and Kyle Fields are in areas of low or very low shipping intensity (OGA 2016).
Oil and gas The Banff and Kyle Fields are in a mature area of the CNS with extensive oil and gas
development. Adjacent oil and gas surface infrastructure within 40 km are as follows
Installation nam e Installation type Operator Distance
Gannet A Platform Shell UK 27 km NW
Triton FPSO Dana Petroleum 26 km W
Elgin Platform Total 32 km E
Franklin Platform Total 30 km E
Shearwater Platform Shell UK 39 km E
Telecommu- There are no active cables in the vicinity of Banff and Kyle. However, the North Sea Link
nication electricity interconnector between Norway and the UK is currently under construction.
The planned cable passes ~2 km from the Kyle Field and will cross the disused Kyle
South to Curlew production pipeline. The cable will be operational by 2021 (North Sea
Link, 2020).
Military There are no designated areas for military activities in the vicinity of Project area. There
activities are no known military restrictions on Blocks 22/27, 29/2 and 29/7 (NMPi, 2020).
Renewables The closest renewables site is ~54 km from the Kyle Field (NMPi, 2020).
Wrecks There are two unknown wrecks approximately 3.5 km NW and 6.7 km due west of the
Banff Field respectively. The (possible) wreck of the Ternacia motor trawler is located
~3.7 km due south of the Banff Field. Another unknown wreck is located <1 km from the
Curlew Field. Neither of these wrecks are listed as dangerous (NMPi, 2020).
3.4 Sensitive Receptors
3.4.1 Seabed
3.4.1.1 Habitats and Benthos
Much of the seabed of the CNS is categorised as EUNIS habitat type A5.27 ‘Deep circalittoral sand’. The
Banff field is located partly within A5.27 ‘Deep circalittoral sand’, and also withi n an area of A5.37 ‘Deep
circalittoral mud’. Directly to the south of the Banff field is a small patch of A5.15 ‘Deep circalittoral coarse
sediment’ (EMODnet, 2019). Survey data confirmed the main sediment type in the Banff field to be EUNIS
broad habitat A5 ‘Sublittoral sediment’. This habitat produces low sonar reflectivity when subjected to side
scan sonar (SSS). Regions of seabed which had higher sonar reflectivity were determined to be habitat type
A5.44 ‘Circalittoral mixed sediment’ (Fugro, 2020a).
In contrast, the Kyle field is almost exclusively located within A5.37 ‘Deep circalittoral mud’ (EMODnet, 2019).
Survey data categorised it as EUNIS broad habitat A5 ‘Sublittoral sediment’ and determined that the sediment
type was homogenous between both the North and South Kyle locations (Fugro, 2020b). Figure 3-2 presents
images taken during surveys which show the seabed type. Each image is numbered and corresponds to a
location marked on Figure 3-1.
The dominant taxa observed during video surveys within both the sandy and mixed substrate at the Banff field,
were sea pens (P. phosphorea), hermit crabs (Paguridae) and anemones (Actiniaria including Hormathiidae
and Epizoanthus papillosus). Other fauna included sea urchins (Echinoidea including Gracilechinus acutus),
nudibranchs (Nudibranchia), starfish (Asteroidea including Asterias rubens and Astropecten irregularis),
brittlestars (Ophiuroidea), crabs (Brachyura), soft coral (Alcyonium digitatum), sea cucumber (Psolus spp.),
sea snail (Naticidae), sea pens (V. mirabilis), worms (Polychaeta), sponges (Porifera), squat lobster

(Galatheoidea), anemones (Ceriantharia) and faunal turf (Hydrozoa / Bryozoa) (Fugro, 2020a). Some
evidence of calcareous tube worms (Serpulidae) was additionally observed in the Banff Field.
The observed benthos associated with the Kyle field was very similar however, sea urchins (Gracilechinus
acutus) were considered amongst the dominant species within the field (Fugro, 2020b). Bioturbation, which
includes faunal tracks, burrows and mounds, was evident across both Fields (as visible in Figure 3-2; Fugro
2020a, 2020b). While these burrows did not indicate the presence of Norway lobster (Nephrops norvegicus),
they do indicate the possible presence of OSPAR listed threatened and / or declining habitat ‘Sea pen and
burrowing megafauna communities’.
According to JNCC (2014a) guidance, the key determinant for classification of ‘Sea pen and burrowing
megafauna communities’ is the presence of burrowing species or burrows at a minimum SACFOR density of
‘frequent’. According to the SACFOR classification, the presence of P. phosphorea ranged from ‘occasional’
to ‘common’ across the sites sampled during the Banff survey. V. mirabilis was ‘frequent’ at one station and
‘absent’ at all others. Faunal burrows between 3-15 cm in size were ’absent’ at nine of 13 stations. At the
remaining stations they were recorded as either ‘frequent’ or ‘common’ (Fugro, 2020a). Sea pens (mostly P.
phosphorea) are clearly visible in the images in Figure 3-2, as are the faunal burrows indicative of the OSPAR
habitat.
Faunal burrows sized 3-15 cm were recorded at all stations and transects within the Kyle North site. Using
the SACFOR classification this was considered either ‘common’ or ‘frequent’. Faunal burrows sized 3-15 cm
were recorded at all stations and transects within the Kyle South site. The SACFOR classification of faunal
burrows here was ‘common’ at all but one site which was considered ‘abundant’. Faunal burrows >15 cm were
‘absent’ at all stations and ‘frequent’ along the visual transects within the Kyle South site (Fugro, 2020b).
231 benthic taxa were counted at Banff and 230 at both Kyle North and South. The dominant taxa which were
identified in the survey samples were common to this region of the North Sea. Just over 40% of the taxa
counted in the Banff and Kyle Fields were annelids each time (Fugro, 2020c). The polychaetes Paramphinome
jeffreysii and Galathowenia oculata were the most abundant taxa across all areas surveyed. Other dominant
taxa included the annelid polychaetes Ampharete falcata, Pholoe assimilis, Spiophanes bombyx, S. k royeri,
Pseudopolydora A, Galathowenia fragilis, the bivalve molluscs Axinulus croulinensis and Adontorhina similis
and the lophophore Phoronis. Ocean quahog are another OSPAR listed threatened and / or declining species.
Samples taken during the surveys of both the Banff and Kyle Fields did not contain any adult specimens (>1
cm). Video footage taken during both surveys also did not identify any siphons of the species (Fugro, 2020a,
2020b). While no adult A. islandica were found, juveniles were found in all but one of the macrofaunal samples
ranging between 1 and 22 juveniles per 0.1 m 2. These dominant taxa are common to this region of the North
Sea (Fugro, 2020c). Based on these findings, it is unlikely that ocean quahog exist in aggregations within the
Fields.
Fish observed in survey footage of both Fields included flatfish (Pleuronectiformes including Glyptocephalus
cynoglossus), Norway pout (Trisopterus esmarkii), gadoid fish (Gadidae), cod (Gadus morhua), haddock
(Melanogrammus aeglefinus), gurnard (Triglidae), and hagfish (Myxine glutinosa; Fugro, 2020c). Norway pout
is listed as a Scottish Priority Marine Feature (PMF).

Figure 3-2 Surv ey images from the Banff and Kyle Fields
Photo 1
Sediment type:
Muddy sand / sandy mud with shell fragments
Fauna:
A. Sea pen (P. phosphorea)
Photo 2
Sediment type:
Fauna:
A. Sea pen (P. phosphorea)
B. Anemone (Ceriantharia)
Photo 3
Sediment type:
Fauna:
A. Sea pen (Virgularia mirabilis) and starfish (Astropecten
irregularis)
B. Dragonet (Callionymus spp.)
Faunal burrows

Photo 4
Sediment type:
Fauna:
A. Sea pen (Pennulata phosphorea and Virgularia mirabilis)
B. Starfish (Astropecten irregularis)
Faunal tracks
Photo from Transect BN_TR02

Sediment type:
Muddy sand / sandy mud with gravel and cobbles
Fauna:
A. Squat lobster (Galatheoidea)
B. Sea cucumber (Psolus spp.)
C. Starfish (Asteroidea)
D. Soft coral (Alcyonium digitatum)
E. Anemone (Hormathiidae)
Faunal turf (Hydrozoa / Bryozoa)
3.4.1.2 Physical Composition

Within the Banff Field, sand was the dominant sediment fraction, contributing on average 84.59% to samples.
Fines content ranged from 9.92% to 22.53%, with a mean of 14.90%. Gravel content ranged from 0.00% to
4.48%, with a mean of 0.51% (Fugro, 2020c). Sand content at Kyle North had a mean of 88.33% across
samples. Fines content ranged from 9.06% to 13.57% at station, with a mean of 11.59%. Gravel content was
very low within all samples (<1.00%). At Kyle South sand content had a mean of 84.31%. Fines content
ranged from 11.55% to 21.01%, with a mean of 15.51%. The gravel content of samples was always <1.00%
(Fugro, 2020c). At most stations sampled within both the Banff and Kyle Fields, the fines content was
consistent with the CNS mean background fines concentration (17.38%), only occasionally exceeding the norm
(Fugro, 2020c). Based on the content of fines, sand and gravel the sediment within both fields was
predominantly classed as muddy sand.
3.4.1.3 Chemical Composition
Sediments across both the Banff and Kyle Fields had a low organic carbon content. Total hydrocarbon content
(THC) values at Kyle North and Kyle South were generally comparable to, or below the average background
concentration typical of the CNS. THC levels at Banff had a mean of 22.5 μg/g and were generally higher than
the levels recorded at Kyle North and Kyle South. THC at Banff exceeded the OSPAR 50 parts per million
(ppm) ecological effects threshold at one sampled station (109 ppm was recorded). The highest THC levels
recorded at Banff correlated with stations where oil-based mud inputs were detected (presented in Figure 3-3,
taken from Fugro, 2020c). This THC distribution indicates the presence of historic cuttings piles. It is not
possible to determine the spread of this THC distribution to a higher resolution; however it is possible that this
is an anomaly linked to the predominant south-easterly currents and associated movement of sediment (and
hydrocarbons) away from the site of the Banff drill-centre. Polycyclic aromatic hydrocarbon (PAH),
polychlorinated biphenyl (PCB) and bioavailable metals were all found in concentrations equivalent to, or
below, what is typical of the CNS. Barium levels did indicate some dispersion of drilling muds around the
Banff, Kyle North and South drill centres, however, where chemical parameters were elevated, there was
limited evidence to suggest this had a negative impact on the macrofaunal community (Fugro, 2020c).

Figure 3-3 Spatial distribution of THC at Banff and Kyle (from Fugro, 2020c)

3.4.2 Conservation Sites

3.4.2.1 Offshore Conservation
The Banff Field is partly located within the East of Gannet and Montrose Fields NCMPA. The NCMPA is
located within a shallow sediment plain where the seabed is dominated by sands and gravels, the preferred
habitat for ocean quahog. Both the species and their supporting habitat are one of the reasons for the area’s
designation. The clam species are usually found beneath the surface of sandy sediments and filter food from
the water. As they can live for over 400 years, they are amongst the longest living creatures on Earth (JNCC,
2017). The aggregations are mostly located along the eastern extent of the site (JNCC, 2014b). None were
identified during the Banff and Kyle surveys (see Section 3.4.1).
The area is also designated for the presence of offshore deep-sea muds. The NCMPA hosts one of the few
examples of coherent Atlantic-influenced offshore deep-sea mud habitat. The deep-sea muds occur in a 2–7
km wide band, which is approximately 100 m deep, and runs from the south-east to the north-west along the
southern border of the NCMPA (JNCC, 2017).
The Conservation Objectives for the East of Gannet and Montrose Fields NCMPA are for the features to remain
in favourable condition or, if they are not in such a condition, to be brought into it (JNCC, 2018a). All other
offshore protected sites are located >100 km from the Banff and Kyle Fields. Figure 3-4 shows the location of
the Banff and Kyle Fields in relation to the conservation areas in the region.
3.4.2.2 Onshore Conservation
The Buchan Ness to Collieston Coast SPA is the nearest onshore conservation site to the Banff and Kyle
fields. The site is designated for breeding seabird assemblages, including the following species: fulmar,
guillemot, herring gull, kittiwake, and shag (SNH, 2017). However, as it is located ~191 km from the Banff field
and ~189 km from the Kyle field, the decommissioning activities are unlikely to have an impact on this site.

Figure 3-4 Conserv ation sites in the v icinity of the Banff and Kyle Fields

3.4.3 Other Users: Commercial Fisheries

This section describes the type of fishing vessels occurring in the area, the weight and value of fish landed
and the fishing effort in the study area over the period 2015 to 2019 in context with the rest of the UKCS. The
study area considered to be relevant for the decommissioning activities is shown in relation to the ICES
rectangles, 42F1 and 43F1 (Table 3-2 and Table 3-3).
According to fishing data from the Scottish Government (2020), the waters surrounding the Banff and Kyle
infrastructure are fished for a variety of species by both UK and foreign vessels. ICES rectangle 42F1 has
predominantly been targeted for shellfish in recent years, whilst the adjacent ICES rectangle 43F1 is mostly
targeted for demersal fishing (Table 3-2). For the period 2015-2019 inclusive, the total landings value was
greater in ICES rectangle 42F1 than 43F1 by £2,383,217, and the live weight of those landings were greater
by approximately 694 Te (Table 3-2).
This observation reflects the dramatically larger tonnage of shellfish s pecies caught in ICES rectangle 42F1,
comprising >50% of the total landings live weight in 2019, and constituting over five times the average live
weight of shellfish landings in 43F1 (between 2015 and 2019; Table 3-2). The total annual landings for the
Banff and Kyle Area (ICES rectangles 42F1 and 43F1) were ≤1% of the total landings within the UKCS for
each of the five most recent fishing years (Scottish Government, 2020).
Total fishing effort in ICES rectangle 42F1 amounted to 251 days in 2019 (Table 3-4). In 2019 fishing effort in
ICES rectangle 42F1 was highest for January, March and November (45, 42 and 42 days respectively),
together accounting for 51% of the total number of days fished. Only the summer months of May, June and
August had fishing effort recorded as disclosive. Overall, this effort can be considered low. In the years
preceding 2018, fishing effort had traditionally been higher during the summer months (Scottish Government,
2020).
Comparatively, fishing effort in ICES rectangle 43F1 is much lower. In 2019, effort was highest in January
(only 6 days), accounting for 21% of the total number of days fished, with the other disclosive months
contributing for the remaining fishing effort. In total there were 28 days of fishing effort in 2019 in 43F1 which
is very low (Table 3-4). Both in 2018 and consistently in past years fishing effort has been greater in rectangle
42F1 compared to 43F1. The catch per unit effort (CPUE) is a measure of the weight of catches versus per
number of effort days (an indirect measure of fish availability). For ICES rectangle 42F1, CPUE was 1.1
Te/day, and for rectangle 43F1 CPUE was higher at 1.5 Te/day. The combined CPUE for both rectangles was
2.5 Te/day, which is just over half the CPUE for the UKCS across the same period (4.1 Te/day; Scottish
Government, 2020).
Trawls were the most utilised gear in rectangle 42F1 and 43F1. In total, trawls contributed 99% of the total
fishing effort in rectangle 42F1. In rectangle 43F1 approximately 86% of total fishing effort was from trawls
with the remainder being attributed to seine nets (Scottish Government, 2020).

Document Title: Banff and Kyle Decommissioning Programme: Environmental Appraisal Report
Table 3-2 Liv e Weight and Value of Fish and Shellfish from ICES Rectangles 42F1 and 43F1 Betw een 2015-2019 (Scottish Gov ernment, 2020)3
2019 2018 2017 2016 2015

ICES
Species Type Liv e Liv e Liv e Liv e Liv e
Rectangle
Weight Value (£) Weight Value (£) Weight Value (£) Weight Value (£) Weight Value (£)
(Tonnes) (Tonnes) (Tonnes) (Tonnes) (Tonnes)
Demersal 100 121,311 53 75,049 67 112,475 153 202,601 66 70,311
Pelagic 0 349 63 25,388 1 1,301 215 104,582 <1 362

42F1
Shellfish 242 842,305 115 484,335 140 602,528 236 1,080,620 83 321,002
Total 343 963,966 195 570,013 209 716,511 604 1,387,803 150 391,674
Demersal 134 149,129 34 41,431 140 181,436 106 136,761 57 64,849
Pelagic 0 90 <1 90 80 33,760 1 967 <1 369

43F1
Shellfish 4 18,736 4 18,828 93 401,357 127 528,622 10 42,065
Total 140 167,865 47 77,901 318 627,351 234 666,349 68 107,284
Total for Both Rectangles 483 1,131,831 242 647,914 527 1,343,862 838 2,054,152 218 498,958
UK Landings Total 493,076 767,721,935 555,565 764,993,805 565,639 724,854,083 564,677 729,378,313 547,423 574,430,209
3
All values are rounded to the nearest whole number. For the purposes of identifying within the UK, disclosive data has not been included to limit
the effects of zero-inflation on the results.
Table 3-3 Annual Fishing Effort by UK Vessels and Landings by All Vessels landing in the UK for the Banff and Kyle Area and Across the UKCS (2015 – 2019)
(Scottish Gov ernment, 2020)4
Within ICES rectangle 42F1 Within ICES rectangle 43F1 Av erage across the UKCS
Year
Fishing effort Landings Liv e Weight Fishing effort Landings Liv e Weight Fishing effort Landings Liv e Weight
(days) v alue (£) (te) (days) v alue (£) (te) (days) v alue (£) (te)
195 391,674 150 55 107,284 68 700 3,001,940 2,841

2015
512 1,387,803 604 272 666,349 234 693 3,599,692 2,785

2016
222 716,511 209 170 627,351 318 638 3,553,440 2,809

2017
210 570,013 195 24 77,901 47 620 3,768,936 2,779

2018
251 963,966 343 28 167,865 140 641 3,800,604 2,441

2019
Annual
Av erage 278 805,993 300 110 329,350 161 658 3,544,922 2,731
4
All values are rounded to the nearest whole number. For purposes of identifying averages across the UK, disclosive data has not been included
to limit the effects of zero-inflation on the results.
Contract BFD399029
Number: Report - Banff and Kyle Decommissioning Programme: Environmental Appraisal Report
Document Title:
Table 3-4 Number of Fishing Days per Month (All Gear) for Vessels Landing into Scotland in ICES Rectangles 42F1
5
and 43F1 Betw een 2015-2019 (Scottish Gov ernment, 2020)
ICES Year Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Total
Rectangle
2019 45 9 42 24 D D 23 D 18 23 42 17 251
2018 99 11 D D D D D 42 D D D 31 221
42F1 2017 51 D D D D 43 34 73 D D D D 223
2016 D D 101 16 94 10 14 51 102 8 18 99 518
2015 D - D D 14 20 - - 39 37 57 D 195
2019 6 D D - D D D D - D D - 28
2018 8 D - - D D - D - D - D 25
43F1 2017 29 - - D D 9 D 116 D D D D 171
2016 D D 20 D 59 - D D 149 14 - 13 272
2015 - D - D D D - D D 11 5 D 55
Vessel automatic identification system (AIS) tracks can indicate what types of fishing activity occur in a region.
Long straight lines of vessel movement suggest vessels are in transit with many vessels leaving from
Peterhead, on the north east coast of Scotland, to reach fishing grounds around the North Sea. According to
2017 AIS data, to the west of the Kyle Field and to the northwest of Banff there appears to be evidence of
fishing activity, based on the tight localised AIS patterns; these pockets could be targeted by demersal fishing
methods, for instance Nephrops trawling, as the AIS lines show intensive back and forth movement in the
same place (Figure 3-5). AIS data from years preceding 2017 showed a higher incidence of fishing vessels in
the vicinity of the Banff and Kyle Fields coming from / departing to Norwegian waters, as well as Peterhead.
Trawling intensity across pipelines is generally low; between 0 – 5 trawl passes across the Banff / Kyle Field
pipelines per year on average (between 2007 – 2015). The pipeline which experiences the most trawling
activity overhead is the disused PL1798 which connects Kyle South to the Curlew Field (Figure 3-6). When
considered in conjunction with the vessel monitoring system (VMS) hotspot areas in Figure 3-7, there are
patches of increased Nephrops fishing intensity at either side of the aforementioned pipeline. The increased
number of passes across the PL1798 could indicate the movement of vessels between those two areas of
Nephrops fishery. To the south west of the disused PL1798 is an area of increased (pelagic) herring fishing
intensity. The visible prevalence of the Nephrops and herring fisheries is apparent when looking at the species
breakdown of catch in ICES rectangles 42F1 and 43F1 (as discussed above and presented in Table 3-2).
5
Monthly fishing effort by UK vessels landing into Scotland: “-“ = no data, D = disclosive data (indicating very
low effort), green = 0-100 days fished, yellow = 101-200 days fished, orange = 201-300 days fished, red = ≥
301.

Contract BFD399029
Document Title:
Figure 3-5 AIS data for commercial fishing v essels during the year (MMO, 2017)

Contract BFD399029
Document Title:
Figure 3-6 Traw ling intensity associated w ith the pipelines to be decommissioned

Figure 3-7 VMS intensity for Nephrops (mobile gear) and herring (pelagic) fisheries in ICES Rectangles 43F1 and 42F1

3.5 National Marine Plan

The National Marine Plan (NMP) covers the management of both Scottish inshore waters (≤ 12 nm) and
offshore waters (12 – 200 nm). The NMP aims to ensure sustainable development of the marine environment
by guiding regulation, management, use and protection of Marine Plan areas. The proposed decommissioning
activities have been assessed against relevant NMP Objectives: GEN 1, 4, 5, 9, 12, 14 & 21; Oil & Gas 1, 2,
3, 5 & 6.
The proposed operations do not contradict any of the marine plan objectives and policies. CNRI will ensure
compliance with all the policies; with particular attention being made to those listed above. The following
Sections describe the aims of each policy and how CNRI commitments will achieve them.
3.5.1 GEN 1 – General planning and principle

Development and use of the marine area should be consistent with the Marine Plan, ensuring activities are
undertaken in a sustainable manner that protects and enhances Scotland’s natural and historic marine
environment. CNRI will ensure that any potential impacts associated with the Banff and Kyle decommissioning
operations will be kept to a minimum.
3.5.2 GEN 4 – Co-existence

Where conflict over space or resource exists or arises, marine planning should encourage initiatives between
sectors to resolve conflict and take account of agreements where this is applicable. CNRI will ensure that any
potential impacts on other sea users associated with the proposed Banff and Kyle decommissioning operations
will be kept to a minimum.
3.5.3 GEN 5 – Climate change

Marine planners and decision makers should seek to facilitate a transition to a low carbon economy. They
should consider ways to reduce emissions of carbon and other greenhouse gasses. CNRI will ensure that any
potential impacts associated with the Banff and Kyle decommissioning operations will be kept to a minimum.
3.5.4 GEN 9 – Natural heritage

Development and use of the marine environment must:
 Comply with legal requirements for protected areas and protected species.
 Not result in significant impact on the national status of PMF.
 Protect and, where appropriate, enhance the health of the marine area.
CNRI will ensure that any potential impacts to protected species and sites associated with Banff and Kyle
decommissioning activities will be kept to a minimum.
3.5.5 GEN 12 – Water quality and resource

Developments and activities should not result in a deterioration of the quality of waters to which the Water
Framework Directive, Marine Strategy Framework Directive or other related Directives that apply. CNRI will
ensure that any potential impacts to water quality associated with the Banff and Kyle decommissioning
operations will be kept to a minimum.
3.5.6 GEN 14 – Air quality

Development and use of the marine environment should not result in the deterioration of air quality and should
not breach any statutory air quality limits. Some development and use may result in increased emissions to
air, including particulate matter and gases. Impacts on relevant statutory air quality limits must be taken into
account and mitigation measures adopted, if necessary, to allow an activity to proceed within these limits.
CNRI will ensure that any potential impacts to air quality with Banff and Kyle decommissioning operations will
be kept to a minimum.

3.5.7 GEN 21 – Cumulative impacts

Cumulative impacts affecting the ecosystem of the marine plan area should be addressed in decision making
and plan implementation. CNRI will ensure that any potential impacts to air and water quality and biological
communities associated with the decommissioning operations within the Banff and Kyle Fields will be kept to
a minimum.
3.5.8 Oil & Gas 1

The Scottish Government will work with DECC, the new Oil and Gas Authority and the industry to maximise
and prolong oil and gas exploration and production whilst ensuring that the level of environmental risks
associated with these activities are regulated. Activity should be carried out using the principles of Best
Available Technology (BAT) and Best Environmental Practice. Consideration will be given to key
environmental risks including the impacts of noise, oil and chemical contamination and habitat change.
3.5.9 Oil and Gas 2

Where re-use of oil and gas infrastructure is not practicable, either as part of oil and gas activity or by other
sectors such as carbon capture and storage, decommissioning must take place in line with standard practice,
and as allowed by international obligations. Re-use or removal of decommissioned assets from the seabed
will be fully supported where practicable and adhering to relevant regulatory process.
3.5.10 Oil and Gas 3

Marine and coastal infrastructure for oil and gas developments and storage should: utilise the minimum space
needed for each activity and take into account environmental and socio-economic constraints.

Consenting and licensing authorities should have regard to the potential risks, both now and under future
climates, to oil and gas operations in Scottish waters, and be satisfied that installations are appropriately sited
and designed to take account of current and future conditions.

Consenting and licensing authorities should be satisfied that adequate risk reduction measures are in place,
and that operators should have sufficient emergency response and contingency strategies in place that are
compatible with the National Contingency Plan and the Offshore Safety Directive.

4 METHODOLOGY
4.1 Overview
This EA is designed to:
 Identify potential impacts to environmental and societal receptors from the proposed decommissioning
activities;
 Evaluate the potential significance of any identified impacts in terms of the threat that they pose to these
receptors; and
 Assign measures to manage the risks in line with industry best practice; and address concerns or issues
raised by stakeholders through consultation.
4.2 Approach
Potential risks associated with the proposed decommissioning operations were assessed during an
ENVironmental Identification (ENVID) workshop attended by project engineers and marine environmental
specialists.
To enable focus during assessment, the potential environmental issues were considered under the following
aspect groups:
 Emissions to air;
 Disturbance to the seabed;
 Physical presence of vessels in relation to other sea users;
 Physical presence of infrastructure decommissioned in situ in relation to other sea users;
 Discharges to sea;
 Underwater noise associated with general decommissioning activities;
 Resource use;
 Onshore activities;
 Waste; and
 Unplanned events.
These aspects were screened in and out of further assessment using two measures, the likelihood of an event
occurring and the consequence of this occurrence. This was done using categories defined within CNRI’s
method of impact assessment.
The likelihood that an event would occur (Table 4-1) and the consequence of an unplanned event occurring
(Table 4-2) were assessed using the definitions specified in the CNRI Management of Aspects and Impacts
Procedure (CNRI, 2018). The consequence of an impact occurring as a result of planned events was assessed
using the definitions specified in the UKOOA Offshore Environmental Statement Guidelines (1999).
The sensitivity of environmental and societal receptors was also considered in the ENVID workshop, taking
into account any sensitive receptors identified (Section 3.4) and the results of the most recent (Fugro, 2020a,
2020b and 2020c) environmental surveys.
4.3 Stakeholder Engagement

The ENVID workshop was undertaken prior to stakeholder consultation, however, the impact assessment
process also captured any long-standing stakeholder views on UKCS decommissioning activities. Stakeholder
concerns from all associated phases of the Banff and Kyle decommissioning were accounted for in this ENVID
(available in Appendix C). A scoping report has been circulated to stakeholders with no feedback to date.

4.4 Impact Assessment Methodology

The following tables outline the approach used to carry out the impact assessment in Section 6.
Table 4-1 Definition of Likelihood of Occurrence (CNRI, 2018)
Likelihood Definition for planned and unplanned events
Very  A freak combination of factors w ould be required for an incident to result.

Unlikely
 An incident has occurred w ithin the UKCS in the past.
 No direct or associated impact on emissions w ill result from process / equipment failure or
malfunction.
Unlikely  A rare or combination of factors w ould be required for an incident to result.

 An incident has occurred on a CNRI platform in the past.
 Unlikely that failure or malfunction of a process / equipment w ill have an impact on emissions.
Possible  Could happen if a number of additional factors are present, but otherw ise unlikely to occur.
 An incident has occurred w ithin the named platform’s lifetime.
 Possible that failure or malfunction of process/equipment w ill impact on emissions.
Likely  Not certain, but incident could occur w ith only one normally -occurring additional factor.
 An incident has occurred w ithin the past year on the named platform.
 Likely that failure or malfunction of process / equipment w ill impact on emissions.
Very Likely  Almost inevitable that an incident w ill occur under the circumstances.
 An incident has happened several times on the platform w ithin the last year or the impact on the
environment is part of a continuous operation. Certain that failure or malfunction of process /
equipment w ill impact on emissions.
Table 4-2 Definition of Consequence of Occurrence (CNRI, 2018 and UKOOA, 1999)
Definition (CNRI, 2018) for an

Severity Definition (UKOOA, 1999) for a planned event
unplanned event
0. None -  No interaction and hence no change expected.
Beneficial -  Likely to cause some enhancement to the

ecosystem or activity w ithin the existing structure.
 May help local population.
1. Negligible  No loss to the external environment.  Change w hich is unlikely to be noticed or

measurable against background activities.
 No regulatory exposure.
 Negligible effects in terms of health or standard
of living.
2. Slight  Potential loss to the external  Change w hich is w ithin the scope of existing
environment from a system or process variability but can be monitored and / or noticed.
does not exceed 1 tonne.
 May affect behaviour, but not a nuisance to users
or public.
3. Moderate  Potential loss to the external  Change in the ecosystem or activity in a localised
environment from a system or process is area for a short time (<2 years), w ith good
betw een 1 and 25 tonnes. recovery potential. Similar scale of effect to
existing variability but may have cumulative
 There is a breach of consent and / or
implications.
legislative conditions w hich is unlikely to
result in prosecution from Regulators.  Potential effect on health, but unlikely.
 May cause nuisance to some users.

Definition (CNRI, 2018) for an

Severity Definition (UKOOA, 1999) for a planned event
unplanned event
4. High  Potential loss to the external  Change in the ecosystem or activity over a w ide
environment from a system or process is area leading to medium term (<2 year) damage,
betw een 25 and 100 tonnes. but w ith a likelihood of recovery w ithin 10 years.
 There is a breach of consent and / or  Possible effect on human health.
legislative conditions w ith potential for
prosecution from Regulators.
 Financial loss to users or public
5. Very High  Potential loss to the external  Change in the ecosystem leading to long-term
environment from a system or process (>10 years) damage and poor potential for
greater than 100 tonnes. recover to a normal state.
 There is a breach of consent and / or  Likely to affect human health.
legislative conditions w ith a strong
likelihood of prosecution from
 Long-term loss or change to users or public
finance.
Regulators.
Table 4-3 Risk Potential Matrix Summary
Severity
Likelihood of
Occurrence
Negligible Slight Moderate High Very High
Very Unlikely 1 2 3 4 5
Unlikely 2 4 6 8 10
Possible 3 6 9 12 15
Likely 4 8 12 16 20
Very Likely 5 10 15 20 25
Table 4-4 Definition of Env ironmental Risk
Score Level of Significance Environmental Risk Definition
1-6 Low Risk Acceptable: review annually and continue with current
management controls
8-12 Moderate Risk should be reduced: Identify opportunities for improvement

through objectives and targets
15-25 High Risk unacceptable: Immediate action required to reduce risk to an

acceptable level
During the ENVID, aspect groups (i.e. underwater noise, seabed disturbance etc…) were scoped in or out of
further assessment based on the level of significance assigned using Table 4-3 and Table 4-4. Any aspect of
a moderate significance (or higher) was scoped in to further assessment. Any known stakeholder concerns
(Section 4.3) and any location-specific environmental and / or societal sensitivities (including cumulative and
transboundary impacts) (Section 3) were also considered when applying a level of significance at this stage.
The full results of the ENVID are presented in Appendix C.

5 IMPACT ASSESSMENT SCREENING AND JUSTIFICATION

The screening of potential environmental impacts from the decommissioning of the Banff and Kyle Fields for further assessment is provided in Table
5-1 , which also includes a rationale for the screening outcomes and any proposed mitigation associated with each aspect group. The potential
impacts on any of the sensitive receptors (described in Section 3.4) are outlined. Further mitigation and measures that will be applied in each
instance against each aspect are also presented. The intention is that such measures should remove, reduce or manage the i mpacts to a point
where the resulting residual significance is reduced to ‘as low as reasonably practicable’ (ALARP).
Table 5-1 Env ironmental Impact Screening Summary for the Banff / Kyle Decommissioning
Mitigation and control Further

Aspect group Rationale
measures assessment?
Emissions to air Emissions during decommissioning activities, (largely comprising fuel  Vessel management. No
combustion gases) will occur following CoP. Emissions generated by
infrastructure, equipment and vessels associated with operation of the  Minimal vessel use/
assets will be replaced by those from vessel use as well as the recycling movement.
of decommissioned materials.  Vessel sharing where
Reviewing historical EU Emissions Trading Scheme data and comparison possible.
with the likely emissions from the proposed workscope suggests that  Engine maintenance.
emissions relating to decommissioning will be minor relative to those
generated during production. The estimated CO2 emissions to be
generated by the selected decommissioning options are 10,654 Te, this
equates to 0.08% of the total UKCS emissions in 2018 (13,200,000 Te;
OGUK, 2019). These emissions have been calculated assuming
approximately 200 days of vessel emissions across the duration of the
project. This vessel time is split across four types of vessels which will
participate in a variety of activities including: flowline removal, rock
placement and a post-decommissioning monitoring. The total emissions
estimate also includes any emissions associated with the infrastructure
being removed and remaining in situ. See Appendix D for a summary of
the emissions associated with the project.
Review of available decommissioning EAs shows conclusively that
atmospheric emissions in highly dispersive offshore environments do not
present significant impacts and are extremely small in the context of UKCS
and global emissions. Most submissions also note that emissions from
short-term decommissioning activities are small compared to those
previously arising from the asset over its operational life. Furthermore, in

line with the OGA’s (2021) expectations, in particular Expectation 11,
CNRI are dedicated to the reduction of greenhouse gas emissions from all
decommissioning operations, as far as is reasonable for each project.
CNRI are committed to working with the supply chain, collating emission /
energy savings initiatives across the business and reviewing emissions
sources, as part of meeting these emissions reduction expectations.
Considering the above, atmospheric emissions do not warrant further
assessment.
Disturbance to  Mitigation to be
There is potential for decommissioning activities to generate disturbance Yes, see
the seabed discussed in Section
to the seabed; these include activities associated with decommissioning Section 6.1
6.1.6
of pipelines in situ with remediation, the removal of substructures and the
surface laid pipeline, and the post-decommissioning remediation of anchor
depressions.
Seabed impacts may range in duration from short-term impacts, such as
temporary sediment suspension or smothering, to permanent impacts,
such as the introduction of new substrate or any consequential habitat or
community level changes which may transpire.
Additionally, seabed disturbance from the removal of infrastructure has the
potential to modify the habitat in a way which might impact upon other sea
users which utilise the seabed. The seabed typical of the Banff and Kyle
Fields may lend itself to the formation of clay berms in areas of
occasionally muddy benthic habitat (described in Section 3.4.1). Clay
berms may pose a potential snagging hazard to commercial fishing gears
which make contact with the seabed. However, the single umbilical
surface laid in a trench is not buried and will be winched up for removal,
thus eliminating the potential for the generation of clay berms.
As pipelines from Groups 1, 2 and 4 will be decommissioned in situ, there
is an associated potential impact of long-term discharges from degrading
infrastructure on the receiving environment. Discharges are expected to
occur in very small quantities and over a long period of time and will be
highly localised as the pipelines will not degrade equally along their length.


Some of the proposed activities will overlap with the East of Gannet and
Montrose Fields NCMPA. The STL piles in Group 8 are all located within
the site, as is one single SAL pile base. The PL1549 is almost entirely
located within the NCMPA. Therefore, any remediation of the ends will
occur within the designated site. The potential impacts to the site are
addressed within Section 6.1.5.
CNRI have elected to undertake a study of the mooring depressions which
remains in the Banff Field as a result of the historic location of the Banff
Petrojarl FPSO (Table 2-6). This will require remediation however, owing
to the slight overlap with the NCMPA, the study will determine the best
course of action to address this, owing to the potentially sensitive seabed
in the area.
CNRI are committed to leaving a clear, safe seabed in the wake of the
decommissioning activities. The clear seabed will be validated by an
independent verification survey over the installation sites and pipeline
corridors. Non-intrusive verification techniques will be considered in the
first instance, but where these are deemed inconclusive by the SFF,
seabed clearance is likely to require conventional overtrawl survey
methods. The methods used will be discussed and finalised with OPRED.
Impacts to the seabed from project activities have been assessed further
in Section 6.1, whilst impacts to commercial fisheries generated by seabed
disturbance are assessed in Section 6.2.
Physical The presence of a small number of vessels for decommissioning activities  Minimal vessel use/ No
presence of will be short-term in the context of the life of the Banff and Kyle Fields. movement.
vessels in Activity will occur using similar vessels to those currently deployed for oil
relation to other and gas installation, operation and decommissioning activities.  Cardinal buoy
sea users Furthermore, all decommissioning works will be carried out within the presence
500 m zones.  Notification to Mariners
The proposed decommissioning of the Banff and Kyle Fields are estimated  Opening up of 500m
to require three different vessel types. These would not all be on location safety exclusion zones
at the same time. Vessel activities are expected to over approximately following seabed-
200 days. clearance.

Other sea users will be notified in advance of planned activities through
the appropriate mechanisms, meaning those stakeholders will have time
to make any necessary alternative arrangements during the finite period
of operations. Furthermore, the Banff and Kyle area only experiences very
low to low shipping levels therefore the decommissioning activities should
not affect shipping and navigation in the region.
Assessment of the impact of the decommissioning on this receptor is
therefore not required.
Physical  Mitigation to be
The physical presence of infrastructure decommissioned in situ has limited Yes, see
presence of discussed in Section
potential of impacting other sea users and is limited to potential snagging Section 6.2
infrastructure risks to commercial fisheries. 6.2.4
decommissioned
in situ in relation The single surface-laid umbilical will be fully removed. Remaining
to other sea structures will be fully removed, and the seabed will be subsequently
users surveyed and remediated as required.
The infrastructure to be decommissioned in situ are the trenched and
buried rigid and flexible flowlines and the trenched and rock-covered rigid
pipelines. Pipeline ends will have mattress cover reinstated and therefore
do not pose an additional snagging risk to other users of the sea.
The burial status of these flowlines is such that they are not expected to
pose any risk of interaction with other sea users (see Appendix E for
exposure details). Future monitoring work will monitor the Depth of Burial
(DoB) of this pipeline and ensure that snagging risks do not arise. The
frequency of this monitoring work and any subsequent maintenance
regime will be established after consultation with OPRED.
CNRI are committed to leaving a clear, safe seabed. The clear seabed
will be validated by an independent verification survey over the installation
sites and pipeline corridors. Non-intrusive verification techniques will be
considered in the first instance, but where these are deemed inconclusive,
seabed clearance is likely to require conventional overtrawl survey
methods. The methods used will be discussed and finalised with OPRED.

To address any Stakeholder concerns and to provide more detail with
regards to the proposed mitigation measures, assessment of potential
snagging risks associated with the decommissioning of infrastructure in
situ, as well as the condition of the seabed following the decommissioning
of infrastructure via full removal, is provided in Section 6.2.
Discharges to All subsea infrastructure in the Banff and Kyle Fields has been drained  MARPOL compliance. No
sea and flushed at CoP. This is a pre-decommissioning activity which has
been permitted as appropriate, and therefore, falls outside the scope of  Bilge management
this EA. procedures.
Vessel discharges are managed through existing legislation and  Vessel audit
compliance controls. Post-flushing and / or water jetting, residual liquids procedures.
present during the decommissioning of pipelines and subsea  Contractor management
infrastructure will be treated before being discharged to sea, such that the procedures.
discharge will comprise treated water. Any residual remaining material will
be in trace levels / volumes following the flushing regime and will not pose
any significant risk to water quality. All residual solids will be shipped to
shore for disposal.
Considering the above, impacts to water quality do not require further
assessment.
Underwater noise Vessel presence will be limited in scale (i.e. the size and number of  Vessel management. No
associated with vessels) and duration, therefore, does not constitute a significant or
general prolonged increase in noise emissions across the project area.  Minimal vessel use/
decommissioning movement.
activities All other noise generating activities associated with the decommissioning
of the Banff and Kyle Fields are considered negligible in the context of  Vessel sharing where
ambient noise levels and are likely to be masked by project-related vessel possible.
activities.  Cutting activities will be
Geophysical surveys undertaken for post-decommissioned infrastructure minimised and carried
left in situ will be assessed in future, through the process of permit out in isolation where
application. Multibeam echosounder survey equipment is likely to be used possible.
for imaging and identification of pipeline exposures. The JNCC (2017)


Guidelines will be employed for mitigation of noise impacts to marine
mammals for future survey work involving seismic survey equipment.
None of the activities associated with the decommissioning of the Banff
and Kyle Fields are considered to generate significant noise levels which
may cause injury or significant disturbance to marine species or other
users. Furthermore, the project is not located within a marine mammal
protection area and EAs for offshore oil and gas decommissioning projects
generally show no potential injury or significant disturbance associated
with the non-survey decommissioning activities covered within the project
scope.
On this basis, underwater noise generated by general decommissioning
activities does not require further assessment.
Resource use Generally, resource use from the proposed activities will require limited  Adherence to the Waste No
raw materials and be largely restricted to fuel use. Any opportunities for Hierarchy
increasing fuel efficiency and reducing use of resources will be identified
and implemented by CNRI where possible.  Vessel management.
The estimated total energy usage for the project is 140,972 GJ. This  Minimal vessel use/
number accounts for all operations, material recycling, and the resource movement.
loss associated with decommissioning items in situ. This is considered  Vessel sharing where
very low, compared to the resources generated during the production possible.
phase of the project. A summary of energy use associated with the project
is available in Appendix D.  Engine maintenance.
Considering the above, resource use does not warrant further
assessment.
Waste The recycling and disposal of wastes are covered by CNRI’s Waste  Overall ‘Duty of Care’ No
Management Strategy, which is compliant with relevant regulations
relating to the handling of waste offshore, transfer of controlled, hazardous  Waste Management
(special) waste, and TFSW (Trans-Frontier Shipment of Waste). Strategy
The Waste Management Strategy is guided by each company’s respective  Active waste tracking
HSE Policy and commitments to best practice in waste management. This (cradle to grave)
includes the mapping and documenting of waste management

arrangements for ongoing monitoring of waste procedures and
performance review against target Key Performance Indicators (KPIs).  Adherence to the Waste
Hierarchy
Wastes will be treated using the principles of the waste hierarchy, focusing
on the reuse and recycling of wastes where possible. Raw materials will  Transfrontier Shipment
be returned to shore with the expectation to recycle the majority of the of Waste (if applicable)
returned material. There may be instances where infrastructure returned  Permitting for hazardous
to shore is contaminated (e.g. by Naturally Occurring Radioactive Material wastes
(NORM), hazardous, and / or special wastes) and cannot be recycled. In
these instances, the materials will require disposal. However, the weight  Communication with
and/or volume of such material is not expected to result in substantial relevant Regulator(s) -
landfill use. e.g. SEPA established
It should be noted that, only licenced contractors which can demonstrate  EEMs tracking
they are capable of handling and processing the material to be brought
 Close-out reporting
ashore will be considered for onshore activities and this will form an
integral part of the commercial tendering process. On this basis, no further  Contractor management
assessment of waste is necessary.
Unplanned Unplanned events may include an unplanned instantaneous diesel  OPEP and TOOPEP in No
events release from the largest vessel. This is expected to be a CSV type vessel, place for operations
with a maximum fuel capacity of approximately 2,000 m 3.
 Navaids (Cardinal
The fuel inventory of the CSV vessel is likely to be split between a number Buoys) in place
of separate fuel tanks, significantly reducing the likelihood of an
instantaneous release of the full inventory. Any spills from vessels in  500m zones operational
transit or participating in decommissioning activities are covered by until seabed clearance
separate Shipboard Oil Pollution Emergency Plans (SOPEPs). CNRI will certified
support response of any vessel-based loss of fuel containment through  SOPEP on all vessels
the vessel owner’s SOPEP.
 Spill response
In line with the mitigation measures in place and the very low likelihood of procedures
occurrence, a vessel collision scenario does not require further
assessment.  Bunkering procedures in
place (if necessary)
In addition to the mitigation measures outlined in the individual vessel
SOPEPs, CNRI maintains manned bridges, navigational aids and


monitoring of safety zones (e.g. with Cardinal Buoys with ‘smart’ location-
sensitive technology). Only project vessels will be present when activity  Contractor management
is taking place within 500 m safety exclusion zone(s). Other vessels will and communication
not be present within the 500 m zone at any time prior to well  Lifting operations
decommissioning, therefore the likelihood of fishing vessels overtrawling management of risk
in the vicinity of the wellheads is negligible, making a well blowout scenario
highly unlikely.  Dropped object recovery
and debris clearance
In line with the mitigation measures in place and the very low likelihood of surveys
occurrence, the well blowout scenario does not require further
assessment.  PON2 submission
As the methodology for the post-removal subsea installation and flowline
return to shore has not been defined in detail, there exists the remote
possibility that during transport of those materials, elements may dislodge
and drop from the transport vessel. Therefore, the likelihood of accidental
loss of pipeline materials to the seabed during lift operations is very low.
Moreover, all subsea installations are considered sound and no issues
regarding their integrity have been identified, therefore methods of
removal are not anticipated to generate issues which result in material
losses to sea.
Dropped object procedures are industry-standard and will be employed.
All unplanned losses in the marine environment will be attempted to be
remediated, and notifications to other mariners will be sent out. The post-
decommissioning Clear Seabed Verification Survey will aid in the
identification of in-field dropped objects.
In line with the mitigation measures in place, unplanned loss of materials
to the sea do not require further assessment.

6 IMPACT ASSESSMENT
The following aspect groups have been identified as requiring further assessment against potential impacts
from the proposed decommissioning activities:
 Disturbance to the seabed; and
 Physical Presence of infrastructure decommissioned in situ in relation to other sea users.
Potential sources of impacts associated with these aspect groups and the consequences for any sensitive
receptors and / or Stakeholders are detailed in Section 6.1 and 6.2.
6.1 Disturbance to the Seabed
6.1.1 Approach
The two seabed impact pathways associated with the proposed activities are direct and indirect disturbance.
Direct disturbance is considered to be the physical disturbance of seabed sediments and habitats. Direct
disturbance has the potential to cause temporary or permanent changes to the marine environment, depending
upon the nature of the associated activity. Permanent impacts are generally considered to represent a worst-
case where required. Activities which contribute to the direct disturbance impact pathway include the removal
of infrastructure and remediation of snagging hazards, either from re-burial or placement of material (rock
armour) on the seabed. The total area of seabed expected to be impacted by direct physical disturbance has
been calculated by adding together the individual areas of physical disturbance estimated for each activity.
Dimensions used to calculate the disturbance area for each activity are available in Appendix A.
The second impact mechanism, indirect disturbance, is that which occurs outside of the direct disturbance
footprint. It may be caused by the suspension and re-settlement of natural seabed sediments and cuttings pile
materials disturbed during activities. This secondary impact pathway is considered temporary in all instances.
The scale of indirect disturbance due to re-suspension and re-settlement of natural sediment has been
estimated based on the expected area of direct disturbance from any activity. The estimated indirect
disturbance area is assumed to be double the direct disturbance area for all installations and activities taking
place.
6.1.2 Sources of Potential Impacts

The following activities have been identified as potential sources of direct or indirect seabed disturbance:
 Subsea infrastructure decommissioning:
o Full removal of subsea structures (Section 6.1.2.1)
o Removal of the STL piles and remediation (Section 6.1.2.2)
o Full removal of spools, jumpers and SSIVs (Section 6.1.2.3)
o Full removal of protection materials (Section 6.1.2.3)
 Decommissioning of rigid and flexible flowlines:
o Decommissioning in situ of trenched and buried / rock covered rigid and flexible flowlines,
including remediation associated with ends and exposures (Section 6.1.2.5)
o Full removal of two surface laid umbilicals (Section 6.1.2.6)
 Remediation of former FPSO mooring locations (Section 6.1.2.7); and
 Clear seabed verification (Section 6.1.2.7).

6.1.2.1 Structures
All subsea structures within the Banff and Kyle Fields are to be fully removed (as described in Section 2.5.3).
Any wellhead structures remaining will be assessed as part of the well decommissioning campaign under
separate permits.
To calculate the area of direct disturbance the dimensions of the structures have been used. To account for
the potential extended impact due to removal methods, the footprint of the base has been doubled. This
methodology has been used in the interest of being conservative and calculating a worst -case possible impact.
An estimate has been made of the possible indirect disturbance due to re-suspension and settlement of
sediment. Most re-suspended sediment will settle within the initial disturbance area, but it has been assumed
that some will land beyond that area. As a conservative estimate, the area of indirect disturbance has been
assumed to be double the area of direct disturbance. This temporary disturbance will be temporary and will
only last as long as activities are occurring.
The direct and indirect disturbance areas associated with these proposed operations are summarised in Table
6-1. A full inventory of infrastructure dimensions is available in Appendix A.
A single SAL Anchor Base associated with the Banff Field is located within the East of Gannet and Montrose
Fields NCMPA. The area of impact associated with the removal of this single item is presented separately
below.
Table 6-1 Seabed Disturbance Associated w ith the Decommissioning of Structures
Indirect
Quantity and Expected duration Direct disturbance
Activity disturbance area
dim ensions of disturbance area (km 2)
(km 2)
Removal of subsea 21 structures of Temporary 0.0021 0.0042

structures in the varying dimensions
Banff Field (not including the
SAL Anchor Base
below)
Removal of Banff Single SAL Anchor Temporary 0.00016 0.00032
Field SAL Anchor Base of dimensions
Base within the 9 m x 9 m x 16.7 m
NCMPA
Removal of subsea 14 structures of Temporary 0.0017 0.0034
structures in the varying dimensions
Kyle Field
Total 0.0038 0.0076
Total within the East of Gannet and Montrose Fields
0.00016 0.00032
NCMPA
The area of direct impact within the East of Gannet and Montrose Fields NCMPA attributed to the removal of
the SAL anchor base is 0.00016 km2 which equates to <0.00009% of the site (1,839 km2).
6.1.2.2 STL Piles
As determined by the CA, Group 8 (consisting of eight STL piles) will be removed below the seabed, requiring
dredging. A full breakdown of the STL pile dimensions is available in Appendix A.6. The seabed impact
footprint of the piles was calculated using the pile dimensions and adding a buffer of 4 m to ensure sufficient
access for cutting. Once the pile sections have been removed, the area will be remediated as appropriate and
under discussion with OPRED, with rock placement within this footprint assessed here as a worst-case
scenario as this would represent a permanent and direct disturbance. As before, the indirect disturbance is
twice the direct disturbance and the indirect impacts are temporary in nature.
The direct and indirect disturbance areas associated with the removal of the STL piles is presented in Table
6-2 below. All eight STL piles are located within the East of Gannet and Montrose Fields NCMPA, therefore
the area of impact associated with their removal is exclusively within the site.

Table 6-2 Seabed Disturbance Associated w ith the Decommissioning of the STL Piles
Indirect
(km 2)
Full removal of the 8 piles of varying Permanent 0.00043 0.00085

STL piles dimensions
Total 0.00043 0.00085
The area of direct impact within the East of Gannet and Montrose Fields NCMPA attributed to the removal of
the eight STL piles is 0.00043 km2 which equates to <0.00002% of the site.
6.1.2.3 Spools, Jumpers, Other Pipeline Sections and SSIVs
As described in Section 2.5.5, all jumpers, spools, other pipeline sections and SSIV structures will be removed.
The area of seabed disturbed by recovery of each individual flowline to the surface has been estimated by
multiplying the length of each individual line section which will be removed, by a 1 m buffer width. The addition
of a buffer aims to account for any disturbance associated with the physical removal process of the spools and
jumpers, and the method by which this activity is undertaken. The areas disturbed by recovery of each
individual line have then been summed to give an overall area of disturbance affected.
To calculate the area of impact associated with the removal of the SSIVs, the footprint of the structure has
been doubled (as for the structures in Section 6.1.2.1) to account for additional disturbance generated by the
structure removal.
Indirect disturbance has been assumed to be twice that of the direct area. This accounts for the resuspension
of sediment generated due to the direct disturbance, most of which will settle within the direct footprint.
However, in light of the muddy sediment composition, the resettlement of sediment is likely to be minimal.
6-3. A full inventory of infrastructure dimensions is available in Appendix A. All disturbance will be temporary
and will only last as long as activities are occurring.
Table 6-3 Seabed Disturbance Associated w ith the Decommissioning of Spools , Jumpers, Other Pipeline Sections
and SSIVs
Indirect
(km 2)
Removal of the 3 SSIVs of Temporary 0.00034 0.00069

SSIVs in the Banff varying
and Kyle Fields dimensions
Removal of spools, 55 items of Temporary 0.12 0.23
jumpers and other varying
pipeline sections in dimensions
the Banff and Kyle
Fields
Total 0.12 0.23
6.1.2.4 Protection (Mattresses and Grout Bags)
Concrete mattresses and grout bags have previously been deployed across the Banff and Kyle Fields to
stabilise and protect the seabed infrastructure. As noted in Section 2.5.7, the intention is that all concrete
mattresses and grout bags will be recovered; this will cause temporary direct and indirect disturbance. Any
protection / stabilisation associated with third party crossing and infrastructure will be left undisturbed and
decommissioned in situ. There are an estimated 1,550 concrete mattresses across the Banff and Kyle Fields
which will be removed. This total allows for an additional mattress contingency should it t ranspire during the
decommissioning activities that there are more mattresses than previously accounted for. The dimensions of
the concrete mattresses were used to determine the area of cover.

In the case of grout bags, there are an estimated 15,500 in the Banff and Kyle Fields. This estimate is likely
to be conservative. Grout bags are used in conjunction with different subsurface installations to provide
protection or stability. As such, they are usually stacked or piled on top of one another or on top of other
installations / mattresses. The exact location and layout of the bags is unknown. Although unlikely, the worst-
case scenario has been defined as all 15,500 bags spread in a single layer on the seabed. A standard grout
bag size has been used to estimate the area cover by grout bags in the Banff and Kyle Fields. Full inventory
details, including the dimensions of stabilisation materials, are available in Appendix A.
The direct and indirect seabed disturbance areas associated with the stabilisation materials are summarised
in Table 6-4. As previously, the indirect impact has been assumed to be double the direct impact area.
Table 6-4 Seabed Disturbance Associated w ith the Decommissioning of Protection Materials
Expected Indirect
Direct disturbance
Activity Quantity and dim ensions duration of disturbance area
area (km 2)
disturbance (km 2)
Removal of Estimated 1,550 concrete Temporary 0.028 0.056

existing mattresses of varying
concrete dimensions
mattresses
Removal of Estimated 15,500 grout bags Temporary 0.0028 0.0056
grout bags of dimensions 0.6 x 0.3 m
Total 0.031 0.061
6.1.2.5 Pipelines Decommissioned in situ
Pipelines from CA Groups 1, 2 and 4 will all be decommissioned in situ and have their ends and exposures
remediated. As remediation is the only anticipated impact associated with the decommissioning of these
groups, the area of impact only relates to the direct and indirect impact due to the placement of rock. As
described in Section 2.5.1, the pipelines will have variable rock placement cover at the ends dictated by the
length of the transition zones (50 m at Banff and 20 m at Kyle). The area of rock placed per end will equate
to either 200 or 500 m2 (using an assumed width of 10 m to account for a 1:3 overtrawlable slope).
Of the eight pipelines in Group 1, five have exposures identified along them, with total length of 345 m. The
remediation activities associated with the decommissioning of the pipelines in situ are considered a permanent
disturbance and represent a worst-case scenario. As before, as a conservative estimate, the indirect
disturbance is twice that of the direct area, however this type of impact is considered temporary. The
permanent direct and temporary indirect disturbance areas associated with these proposed operations are
summarised in Table 6-5. A full inventory of infrastructure dimensions is available in Appendix A.
Table 6-5 Area of Seabed Impact Associated w ith the Remediation of CA Groups 1, 2 and 4
Perm anent Tem porary

Expected
direct indirect
Activity Quantity and dim ensions duration of
disturbance disturbance
disturbance
area (km 2) area (km 2)
Group 1 remediation 16 ends (across eight pipelines), Permanent 0.0062 0.012

of ends 50 m2 per cut end
Group 1 remediation 345 m of exposures (23 Permanent 0.0035 0.0069
of exposures exposures across five pipelines)
Group 2 remediation 12 ends (across six pipelines), Permanent 0.0049 0.0098
Group 4 remediation 4 ends (across two pipelines), Permanent 0.0014 0.0028
Total (permanent) 0.016 n/a
Total (temporary) n/a 0.032

The area of impact associated with the lengths of Group 1, Group 2 and Group 4 being decommissioned in
situ has been calculated below. This has been calculated using the exact dimensions of the pipelines. There
is no disturbance associated with this area, this is currently the area that the Banff and Kyle Field pipelines
occupy and will continue to do so once they are decommissioned in situ.
Table 6-6 Area of Seabed Impact Associated w ith the Decommissioning in situ of CA Groups 1, 2 and 4
Rem aining pipeline

Activity Quantity and dim ensions
infrastructure area (km 2)
Group 1 decommissioned in situ 8 pipelines of varying dimensions 0.010

Total 0.020
A single pipeline (PL1549) is located almost entirely within the East of Gannet and Montrose Fields NCMPA
(Figure 6-1). The area associated with the decommissioning of this pipeline in situ has also been calculated
separately within the context of the NCMPA in Table 6-7 (please note, this area has also been incorporated
into the overall Group 4 area remaining in situ in Table 6-6 above). There are no exposures along the PL1549
but both ends will be covered in rock. Figure 6-1 shows the pipeline within the context of the NCMPA. Although
it appears that the ends of the pipeline are not within the site, to allow for a worst-case scenario, the calculations
assume the entire length of the P1549 to be within the NCMPA, including the ends. The area of rock
associated with the remediation of the pipeline ends has been accounted for separately, as presented in Table
6-7.
Table 6-7 Area of Seabed Associated w ith the Legacy Impact of Decommissioning the PL1549 in situ
Rem aining pipeline Area of rock Area of tem porary

infrastructure area rem ediation w ithin indirect im pact w ithin
Pipeline Dim ensions w ithin East of Gannet East of Gannet and the East of Gannet and
and Montrose Fields Montrose Fields Montrose Fields
NCMPA (km 2) NCMPA (km 2) NCMPA (km 2)
PL1549 6,268 m long, 0.00095 0.0001 0.0002

168.3 mm OD
2 ends, 50 m2 per
cut end
Total 0.00095 0.0001 0.0002
The area of direct impact within the East of Gannet and Montrose Fields NCMPA attributed to the remediation
of the PL1549 ends is 0.0001 km2 which equates to <0.00001% of the site.

Figure 6-1 Pipelines w ithin the Banff and Kyle Fields

6.1.2.6 Pipelines to be Fully Removed

The two umbilicals from CA Group 3 will be fully removed by being winched onto a CSV. The area of impact
associated with this removal has been calculated by multiplying the length of the umbilical by a corridor width
(10 m) of assumed impact which may be generated as a result of the removal procedure used to decommission
the umbilical.
As before, an estimate has been made of the possible indirect disturbance due to re-suspension and
settlement of sediment. The area of indirect disturbance is considered to be double the area of direct
disturbance.
6-8. A full inventory of infrastructure dimensions is available in Appendix A.
Table 6-8 Area of Seabed Associated w ith the Decommissioning of CA Group 3
Direct Indirect
Expected duration of
Activity Quantity and dim ensions disturbance area disturbance area
disturbance
(km 2) (km 2)
PLU4522 1,600 m long, 83 mm OD, Temporary 0.016 0.032

width buffer of 10 m to
account for removal
PLU3106 536 m long, 76.2 mm OD, Temporary 0.0054 0.011
width buffer of 10 m to
account for removal
Total 0.021 0.043
6.1.2.7 FPSO Mooring Remediation
As explained in Section 2.5.5, targeted remediation is anticipated to be required for the mooring trenches and
anchor depressions left by the FPSO mooring lines. However, due to the type of sediment, and with the
intention of having as minimal an impact as possible, the method of remediation has yet to be determined.
CNRI have committed to leaving a safe and unobstructed seabed and intend to commission a study to
determine the appropriate method of remediation for the depressions. Based on the results of the discussion,
CNRI will engage with the regulator to determine this method of remediation. As and when appropriate, these
activities will be permitted and / or covered by a Marine Licence.
However, in the interest of presenting a worst-case scenario with regards to the extent of impact on the seabed,
the mooring trench and anchor depression dimensions have been used to calculate an area of impact. These
dimensions are in Table 2-6 and Table 2-7. The estimated tonnage of rock required for this activity, and the
possible area of rock cover is provided in Table 2-8. While the study has yet to determine the appropriate
method of remediation, the worst-case instance would involve rock placement within the trenches; a permanent
impact. As before, the indirect area is twice the direct area. The area associated with the placement of rock
to remediate the mooring trenches is shown in Table 6-9 below. The total area in Table 2-8 has been used in
the table below.
Figure 2-2 shows the mooring trenches and anchor depressions which overlap with, or are located within, the
East of Gannet and Montrose Fields NCMPA. The area of rock associated with any sections of trench/anchor
depressions which overlap with the NCMPA is calculated separately below.

Table 6-9 Area of Impact Associated w ith FPSO Mooring Remediation
Expected Direct Indirect

Activity Quantity and dim ensions duration of disturbance area disturbance area
disturbance (km 2) (km 2)
Remediation of Remediation of mooring Permanent 0.010 0.020

the mooring trenches 4, 5, 6, 7, 8, 9,
trenches outside 10 and 131.94 m of the
of the NCMPA trench associated with
mooring line 3
Remediation of Remediation of mooring Permanent 0.00062 0.0013
the mooring trenches associated with
trenches within mooring lines 1 and 2 and
the NCMPA 5.06 m of the trench
associated with mooring
line 3
Remediation of Remediation of anchor Permanent 0.0022 0.0045
the anchor depressions 5, 6, 7 and 8
depressions
outside of the
NCMPA
Remediation of Remediation of anchor Permanent 0.0024 0.0048
the anchor depressions 1, 2, 3, 4, 9
depressions and 10
within the
NCMPA
Total 0.012 0.025
Total within the East of Gannet and Montrose Fields NCMPA 0.0030 0.0061
The area of direct impact within the East of Gannet and Montrose Fields NCMPA attributed to the remediation
of the FPSO mooring trenches and anchor scour is 0.0061 km2 which equates to 0.0003% of the site.
6.1.2.8 Clear Seabed Verification
As explained in Section 2.7.1, a clear seabed verification survey is required following all decommissioning
projects to ensure there is no residual risk to other sea users, particularly those who make contact with the
seabed, such as trawl fisheries.
Non-intrusive seabed clearance verification techniques will be considered in the first instance, but where these
are deemed inconclusive, seabed clearance may require conventional overtrawl survey methods. Where there
is evidence of residual snagging hazards (e.g. any berms, dropped objects, etc.), then intervention in the form
of overtrawling to re-level the seabed will be implemented.
Although an important activity for limiting the potential for safety hazards, the use of overtrawling often
constitutes the greatest potential temporary impact to the benthic environment from decommissioning
activities. Therefore, post-decommissioning, CNRI will seek to engage with OPRED to determine the most
effective course of action with regard to clear seabed verification.
6.1.2.9 Summary of Disturbance to the Seabed
The seabed disturbance from the decommissioning activities calculated throughout this Section is summarised
in Table 6-10. This illustrates a worst-case scenario for seabed disturbance, in which the majority of the
seabed impact is associated with the removal of spools, jumpers and SSIVs.

Table 6-10 Total Potential Seabed Disturbance from the Decommissioning Activ ities
Tem porary Tem porary Perm anent

Tem porary Tem porary Perm anent direct indirect direct
direct indirect direct disturbance disturbance disturbance
Activity
disturbance disturbance disturbanc area w ithin area w ithin area w ithin
area (km 2) area (km 2) e area (km 2) the NCMPA the NCMPA the NCMPA
(km 2) (km 2) (km 2)
Removal of 0.0038 0.0076 - 0.0016 0.0032 -

structures
Removal of eight - - - 0.00085 0.00043
STL piles
Removal of spools, 0.12 0.23 - - - -
jumpers and SSIVs
Removal of 0.031 0.061 - - - -
protection
(mattresses and
grout bags)
Remediation of - 0.032 0.016 - 0.002 0.001
Group 1, 2, and 4
pipelines
decommissioned in
situ
Full removal of 0.021 0.043 - - - -
Group 3 umbilicals
Remediation of - 0.025 0.012 - 0.0061 0.0030
FPSO mooring
trenches and
anchor depressions
Total 0.18 0.40 0.028 0.0016 0.012 0.0044
6.1.3 Effects on Sensitive Receptors

6.1.3.1 Direct Disturbance
Decommissioning activities are expected to lead to two types of direct physical disturbance. The first is
temporary disturbance, which will result from the removal of pipelines and infrastructure from the seabed, and
the placement of protective material. The sediment will be disturbed by the action of retrieving equipment from
the seabed and rock placement, but once decommissioning is complete, the affected areas will be free of
anthropogenic material. However, in the case of rock placement, temporary disturbance will only apply to the
wider area impacted by suspended sediments, not the area covered by rock. Temporary disturbance should
allow recovery in line with natural processes such as sediment re-suspension and deposition, movement of
animals into the disturbed area from the surrounding habitat, and recruitment of new individuals from the
plankton.
The second type of direct disturbance will be permanent disturbance caused by the deposition of additional
rock armour on the seabed to protect infrastructure decommissioned in situ. This type of disturbance will
effectively change the seabed type in the affected areas from the naturally occurring sand and mud (as
described in Section 3.4.1) to a hard substrate. These materials will be permanently left on the seabed and
ultimately will become fully buried by the deposition of new natural sediment. While the seabed will eventually
recover and the substrate will return to pre-disturbance conditions, the time frame over which this occurs is so
long-term that the disturbance is considered permanent. The temporary and permanent seabed effects
associated with direct disturbance are discussed in the subsections below.

6.1.3.1.1 Temporary Direct Disturbance

As noted in Table 6-10, approximately 0.18 km2 of seabed would be affected by temporary direct disturbance.
The scale of the disturbance is minimal when compared to other forms of disturbance that occur in the area,
such as commercial trawling. A commercial trawler with a 12 m wide beam trawl trawling at its slowest rate of
approximately 4.7 km/h would cover an area of roughly 0.06 km 2 per hour so would therefore take
approximately 3 hours to cover the anticipated direct disturbance area (FAO, 2019). As stated in Section 3.4.3,
fishing effort in ICES rectangles 42F1 and 43F1, within which the Banff and Kyle Fields are located, is generally
low. Effort in ICES Rectangle 42F1 was higher than in 43F1 and amounted to 251 days in 2019 (6,024 hours).
Despite fishing activity being relatively low, in this context, the extremely limited scale of the disturbance
associated with the decommissioning activities is clear.
Decommissioning disturbance will cause mortality, due to injuries arising from the crushing of benthic and
epibenthic fauna which are sedentary or unable to move quickly. Mobile fauna will likely also be disturbed.
The sediment structure, including the burrows of any animals present, will be affected. Past s urveys of the
Banff and Kyle Fields have identified the most common taxa living on the surface of the seabed as: sea pens
(P. phosphorea); hermit crabs (Paguridae); anemones (Actiniaria including Hormathiidae and Epizoanthus
papillosus), and sea urchins (Gracilechinus acutus; Fugro, 2020a). The polychaetes Paramphinome jeffreysii
and Galathowenia oculata were the most abundant taxa in terms of species identified within grab samples
(Fugro, 2020a, 2020b, 2020c).
The primary feature of conservation concern in the Banff and Kyle Fields are seapens and their associated
EUNIS habitat, ‘Seapens and burrowing megafauna in circalittoral fine mud’ (which falls within the broader
OSPAR threatened or declining habitat ‘Seapen and burrowing megafauna communities'). Burrows were
mostly ‘common’ throughout the area but were considered ‘abundant’ at one site in the Kyle Field (see Section
3.4.1 for a full description of the seabed habitats and benthos). Seapens have some resistance to being
disturbed and generally can reinsert themselves into the sediment if removed, as long as they remained
undamaged. However, damaged individuals show poor recovery, and therefore resilience is considered low,
giving an overall sensitivity of medium (Hill, Tyler-Walters and Garrard, 2020). As such, temporary disturbance
is expected to cause some mortality to any seapens that are physically damaged during operations, but this is
expected to be extremely localised and not have any effect on the viability of the local population. Replacement
of damaged individuals would be expected to occur either from plankton or from “adult” seapens moving in
from the surrounding area. Where there has been a disturbance but the seapens remain undamaged, recovery
may be rapid (<2 years; Hill, Tyler-Walters and Garrard, 2020). The nature of the activities is such that the
removal of subsea structures should only have a highly localised impact on t he seabed, there will be no
placement of items thus the crushing of benthos is unlikely. Given this, recovery of seapens, and their
corresponding habitat, would be swift.
The Banff infrastructure partially overlaps the East of Gannet and Montrose Fields NCMPA. The site is
designated for deep-sea muds and ocean quahog (see Table 3-1). However, no adult ocean quahog (A.
islandica, >1 cm) were recovered within either of the Banff or Kyle surveyed areas. Furthermore, the presence
of ocean quahog siphons was not observed in any of the survey footage (Fugro, 2020a, 2020b). The Banff
Field is located partly within an area of A5.37 ‘Deep circalittoral mud’ and the Kyle Field is almost exclusively
located within A5.37 ‘Deep circalittoral mud’. The JNCC Advice on Operations within the NCMPA categorises
deep-sea muds as ‘sensitive’ to decommissioning activities such as abrasion and disturbance of the substrate,
water clarity and siltation (JNCC, 2018b). The seabed disturbance in relation to this protected site which may
overlap with the activities is detailed in the Section 6.1.5 below.
EUNIS habitat types A5.27 ‘Deep circalittoral sand’, A5.27 ‘Deep circalittoral sand’, and A5.37 ‘Deep
circalittoral mud’ are representative of the Banff and Kyle Fields (EMODnet, 2019). In particular, habitat A5.27
‘Deep circalittoral sand’, the predominant seabed type, is one of the most prevalent seabed habitats in the
North Sea, covering an approximate area of 150,506 km 2 throughout UK waters (NMPi, 2020). As such,
temporary disturbance of a small area of seabed (<0.0001% of the total habitat) is expected to have a negligible
effect in the context of the regional environment.
Though no cuttings piles are evident in the project area, sediment contamination levels indicate the presence
of historic piles. The historic drill cuttings piles within the Banff and Kyle Fields are thought to cover an area
of 4,886 m2 and 4,271 m2 respectively. Drilling fluid inputs were evident at some of the locations within the
Banff and Kyle Fields (Fugro, 2020c). The distribution of THC at sample locations within the Banff and Kyle

Fields is shown in Figure 3-3 (from Fugro, 2020c). At all but one site in the Banff Field the level of THC was
below the OSPAR threshold of ‘ecological effect’ (Fugro, 2020c). However, this being the case at only one
site, the likelihood of the decommissioning activities disturbing this is unlikely. Particularly given the very small
area of overall effect and the highly localised activities which will be occurring to remove the subsea
infrastructure. Based on the location of the structures which will be removed within the scope of this EA, it is
unlikely that the activities will be occurring in proximity to the areas where the THC concentration is highest
(Figure 3-3).
6.1.3.1.2 Permanent Direct Disturbance

Permanent direct disturbance will occur due to placing further hard substrate on the seabed in perpetuity.
Approximately 0.028 km2 of seabed will be subject to permanent direct disturbance due to the introduction of
rock.
The immediate effect of the introduction of new hard substrate will be mortality and injury of benthic and
epibenthic fauna that cannot move away from the activities, as well as disturbance of motile fauna. Following
the introduction of the material, the ongoing effect will be the change of an area of softer habitat to a hard
substrate, and a related change in the types of organisms that can use the habitat. Organisms such as sea
pens and burrowing bivalves, anemones and crustaceans will no longer be able to use the area affected, while
new habitat will be created for other groups such as encrusting sponges and other species of anemone.
The “Seapens and burrowing megafauna in circalittoral fine mud’ habitat has no resistance to physical loss or
change of substrate – where the soft sediment is no longer available, the community ceases to exis t. As
mentioned previously, seapens themselves show poor recovery when physically damaged (Hill, Tyler-Walters
and Garrard, 2020). While the habitat could be affected by the remediation activities, this represents a highly
localised impact. Furthermore, the prevalence of the habitat in the surrounding Banff and Kyle area would
ultimately enable recovery of seapens.
There will be a maximum of 0.0044 km2 of permanent disturbance associated with rock placement inside the
East of Gannet and Montrose Fields NCMPA. This area is associated with the remediation of the PL1549
ends, remediation of the STL pile locations (once they are removed) and the, as yet unconfirmed, worst-case
rock remediation of the FPSO mooring trenches and anchor depressions that overlap the NCMPA. Further
discussion of impacts within the NCMPA can be found in Section 6.1.5.
As mentioned in Section 6.1.2.7, CNRI are committed to undertaking a study which aims to identify the
appropriate method of remediation for any seabed depressions. This is due to the potentially sensitive nature
of the seabed. Therefore, it is possible that rock will not be the chosen remediation method for these features
and so the area of impact calculated is likely to be a considerable over-estimate. Once the survey is complete,
the results will be relayed to OPRED and a discussion will be opened regarding the appropriate method of
remediation for the mooring trenches.
While the introduction of hard substrate clearly results in a change in the habitat type and associated fauna
present, the scale of the impact is negligible considering the very large extent of sandy seabed available in the
CNS. Recovery of the affected areas is expected to take many years but will eventually occur as the deposited
rock material is gradually buried by natural sediment deposition (however the time period is such that this is
still considered a permanent disturbance). Therefore, the community is expected to recover and revert to pre-
disturbance composition with time.
6.1.3.2 Indirect Disturbance
Indirect disturbance (being twice the area of direct disturbance) is projected to have an area of impact of
0.40 km2. The temporary indirect disturbance area of increased sediment in the water column is expected
dissipate rapidly as generally it is the coarser, upper layers of sediment that would be disturbed. Considering
that the fines content of the samples taken throughout the Banff and Kyle Fields was always <25% and given
the small area of impact, the overall level of re-suspended sediment will be low. However, increased
suspended sediment may reduce feeding efficiency of filter feeders due to clogging of feeding structures.
However, though not well studied, the bioturbation associated with burrows will generate sediment
resuspension, thus implying that species typical of the ‘Sea pen and burrowing megafauna communities’
habitat may have some natural tolerance to sedimentation (Hill, Tyler-Walters and Garrard, 2020).
Experimental evidence suggests that seapens, the main filter feeder of concern in the Banff and Kyle Fields,

are not sensitive to increased suspended sediment. Both species observed in the area (P. phosphorea and
V. mirabilis) are tolerant to heavy smothering and siltation. V. mirabilis in particular are capable of retracting
into their burrows thereby cleaning themselves of excess sediment by the production of mucous within the
burrow (Hill, Tyler-Walters and Garrard, 2020). As such, effects due to increased suspended sediment are
not expected to impact the benthos of the Banff and Kyle Fields.
6.1.3.3 Impact of Pipelines Decommissioned in situ
The decommissioning of items in situ has associated legacy impacts. This arises from the gradual breakdown
of materials left in situ. In this instance, 15 pipelines will undergo long-term structural degradation caused by
corrosion, leading to the eventual collapse of the pipelines under their own weight and that of overlying pipeline
coating material, scale and sediment. During this process, degradation products derived from the exterior and
interior of the pipe will breakdown and potentially become bioavailable to benthic fauna in the immediate
vicinity.
The primary degradation products will originate from the following pipeline components:
 Pipeline scale;
 Steel;
 Sacrificial anodes; and
 Plastic coating.
As the Banff and Kyle Field pipelines have already been purged and flushed prior, the pipeline contents is
limited to treated seawater and so is not discussed further herein.
Heavy Metals
Metals with a relatively high density or a high relative atomic weight are referred to as heavy metals. It is
expected that these metals will be released into the sediments and water column during the breakdown of the
components of the pipeline scale, steel and sacrificial anodes.
The toxicity of a given metal varies between marine organisms for several reasons, including their ability to
take up, store, remove or detoxify these metals (Kennish, 1997). Concentrations of the metals are not
expected to exceed acute toxicity levels at any time owing to the decommissioning. However, chronic toxicity
levels may be reached for short periods within the interstitial spaces of the sediments or in close proximity to
the pipelines. At these levels, heavy metals act as enzyme inhibitors, adversely affect cell membranes, and
can damage reproductive and nervous systems. Changes in feeding behaviour, digestive efficiency and
respiratory metabolism can also occur. Growth inhibition may also occur in crustaceans, molluscs,
echinoderms, hydroids, protozoans and algae (Kennish, 1997). It is expected that any toxic impacts will be
short lived and localised with minimal potential to impact populations of marine species. The potential for
uptake and concentration of metals would also be limited to the local fauna and due to the slow release of
these chemicals not likely to result in a significant transfer of metals into the food chain.
The slow release of the metals associated with the pipeline steel and steel associated with the concrete coating
and mattress protection is expected to have a negligible impact on the local environment. It is anticipated that
failure of the pipelines due to through-wall degradation would only begin to occur after many decades (of the
order of 60 to 100 years) (HSE, 1997).
Along buried pipeline corridors there may be accumulations of heavy metals in the sediments. Where present,
the finer fraction of these sediments (silts and clays) are likely to form bonds with these metals, making them
less bioavailable to marine organisms. The sandy (coarser fraction) of the sediments surrounding the pipelines
are less likely to retain metals (MPE, 1999). The seabed within the Banff and Kyle Fields is largely composed
of muddy sand and is therefore likely to retain any metals, prolonging their release to the surrounding seawater.
The pipelines to be decommissioned in situ cover 0.019 km2 within the context of the wider CNS. Degradation
is unlikely to occur at a constant rate and across the entire length of the pipeline. Therefore, due to the highly
localised nature of any degradation products and the low concentrations of contaminants being releas ed over
an elongated period it is highly unlikely that these products will be detectable above current background
conditions.

Plastics
There are plastic components within the composition of the pipelines within the Banff and Kyle Fields.
However, as no micro-organisms have evolved to utilise chemically resistant polymer chains as a carbon
source, these plastics can be expected to persist in the environment for centuries (OGUK, 2013). As the rate
of biodegradability in the marine environment is also low, it can be assumed that the environmental effect of
leaving these plastics in place is insignificant (MPE, 1999).
Due to the highly localised nature of any degradation products and the low concentrations of contaminants
being released over an elongated period it is highly unlikely that these products will be detectable above current
background conditions in the area.
6.1.4 Cumulative and Transboundary Impacts

The decommissioning activities outlined within DP 2 will not act cumulatively with the removal of the FPSO
and FSO, covered by DP 1. No impact to the seabed occurred as a result of the DP 1 activities therefore there
is no opportunity for cumulative impacts within the overall Banff and Kyle decommissioning strategy.
The decommissioning activities taking place within the Banff and Kyle Fields will not be occurring in close
proximity to any other third-party oil and gas installations; the closest installation is the Gannet A platform
(operated by Shell UK) which is located 27 km NW from the proposed activities . At present, there are no active
cables within the vicinity of Banff and Kyle. However, the North Sea Link electricity cable is currently under
construction and passes within 2 km of the Kyle Field. The cable is currently under construction and should
be operational by 2021 (North Sea Link, 2020). Cable installation activities will not coincide with the proposed
Banff and Kyle decommissioning (schedule available in Section 2.4). Thus, cumulative impacts on the seabed
cause by construction and decommissioning activities are considered negligible.
The Banff and Kyle Fields are located 65 km and 73 km respectively from the UK / Norway median line. Given
this distance, and the area of indirect temporary disturbance being 0.17 km2, there is no potential for sediment
to travel beyond the immediate vicinity of the decommissioning area and into neighbouring territorial waters.
The potential for seabed transboundary impacts is therefore highly unlikely.
6.1.5 Potential Impacts to Protected Sites

The Banff Field is partially located in the East of Gannet and Montrose Fields NCMPA. The site is designated
for deep-sea muds and ocean quahog. A number of decommissioning activities have the potential to affect
the site directly, as follows:
 Remediation of the PL1549: The PL1549 is almost entirely located in the NCMPA and is already covered
by rock protection. The pipeline does not have any exposures; therefore, the only remediation required
will be along the pipeline ends (500 m2 per end). This will be a permanent source of impact.
 Remediation of the FPSO mooring trenches and anchor depressions: As shown in Figure 2-2, targeted
remediation will be required within the NCMPA to address some of the mooring trenches (associated with
mooring lines 1, 2 and 3) and anchor depressions (associated with mooring lines 1, 2, 3, 4, 9 and 10)
which remain as a legacy from the former location of the FPSO. While a worst-case assumption of rock
placement has been considered throughout the EA, the final method of remediation will be fully
investigated in the proposed seabed study and any actions to undertake remediation will be discussed
with OPRED and covered by the appropriate permits.
 Removal of eight STL piles in the Banff Field and the remediation of their former location: This area will
relate directly to the structure footprints and any surrounding excavation required to allow for cutting and
removal. Once removed, the area will be remediated, with a worst-case scenario of rock remediation
resulting in a permanent impact to the seabed.
 Removal of a single Banff SAL Anchor Base: The removal of the single structure will only generate a
temporary direct and indirect impact.
As quantified in Section 6.1.2.7, an estimated 0.003 km2 of rock will be required within the NCMPA to remediate
the mooring trenches and anchor depressions within the site, and those which partly overlap the site’s

boundary. These unconfirmed remediation activities constitute the biggest impact to the site. A further
0.001 km2 of rock will be used to remediate the ends of the PL1549, and an estimated 0.00043 km2 of rock will
be used to cover the former STL pile locations. All this activity will result in a total area of permanent impact
of 0.0044 km2 (Table 6-10). As stated previously, this is likely to be an overestimate because the seabed study
has yet to determine the appropriate course of action to remediate the mooring trenches. Additionally, as can
be seen in Figure 6-1, the ends of the PL1549 may be outside the boundary of the NCMPA thus in reality, a
much lesser area of the site may be affected by these decommissioning activities.
The East of Gannet and Montrose Fields NCMPA site covers an area of 1,839 km 2 (JNCC, 2017). Activities
which will generate a permanent impact on the site, and consequently a loss of habitat, will affect an area
equating to 0.0002% of the site. Activities relating to the removal of the single SAL Anchor Base will create a
maximum area of temporary direct disturbance equating to <0.00009% of the site. Consequently, only a very
small area will be subject to disturbance due to the proposed activities. In the case of temporary disturbance,
the area affected is likely to recover once the activities cease. It is also possible that with regard to remediation
of the FPSO mooring trenches and anchor depressions, rock infill would not be all the way up to seabed level;
this would allow for some natural backfilling by sediment to cover the rock over time. This would enable some
degree of seabed recovery. However, the final method of remediation has not been determined and any future
activities relating to the mooring trenches and anchor depressions in the Banff Field will be covered by the
applicable permitting once confirmed with OPRED.
Based on the estimated locations of aggregations of ocean quahog and deep-sea muds, the decommissioning
activities are only at risk of impacting the deep-sea mud habitat (NMPi, 2020). The JNCC Advice on Operations
within the NCMPA categorises deep-sea muds as ‘sensitive’ to decommissioning activities such as abrasion
and disturbance of the substrate, water clarity and siltation (JNCC, 2018b).
However, as described in Section 3.4.1, the environmental surveys carried out across the Banff Field defined
the sediment as still having a substantial sand component (on average 84.59%; Fugro, 2020a). While the
survey coverage within the Banff Field was centred on the Banff manifold (Figure 3-1) and did not extend as
far from this location as the FPSO mooring trenches and anchor scour, it is possible that the trenches and
depressions are in areas of localised sand sediment. Consequently, it is possible that the Banff Field may not
intrude into an area of deep-sea muds as recognised within the NCMPA. As such, the protected deep-sea
mud habitat may not be affected by the proposed decommissioning activities. Conversely, the depth of some
of the trenches (as reported in Table 2-6) are such that it is possible the substrate has a substantial mud
component as only a stiff clay could support such seabed features.
Overall, the impact on the NCMPA, including temporary and permanent direct impacts, will affect 0.0003% of
the site, which is not likely to impact the functionality of the habitat. The Conservation Objectives of the site
aim to maintain favourable conditions within the site or bring them into this favourable condition. It is not
anticipated that the impact of the proposed decommissioning activities would inhibit the ability of the s ite’s
condition to be improved or reduce the condition of the site overall. As described above, the area of impact is
likely an overestimate and surveys of the area did not observe any habitats for which the site is designated.
Therefore, the most sensitive habitats of the NCMPA may be minimally affected by the decommissioning of
the Banff and Kyle Fields.
With respect to cumulative impacts on the NCMPA, at time of writing CNRI are not aware of any similar projects
occurring nearby within the same timeline or otherwise. There are a number of other oil and gas developments
in the NCMPA: the East of Gannet and Montrose Fields; the Gannet Fields; and the Arwkright, Wood, Madoes,
Montrose and Teal Fields. However, none of these have submitted DPs therefore it is assumed that there are
no significant planned activities due to take place in the nearby future within the site. Thus, opportunities for
cumulative impacts are eliminated.
6.1.6 Mitigation Measures

The following measures will be adopted to ensure that seabed disturbance and its impacts are minimised to a
level that is as low as reasonably practicable:
 All activities which may lead to seabed disturbance will be planned, managed and implemented in such a
way that disturbance is minimised;

 Careful planning, selection of equipment, and management and implementation of activities;

 A debris survey will be undertaken at the completion of the decommissioning activities. Any debris ident ified
as resulting from oil and gas activities will be recovered from the seabed where possible;
 Rock armour will be placed by a fall pipe vessel equipped with an underwater camera on the fall pipe. This
will ensure accurate placement of the rock armour and reducing unnecessary spreading of the rock armour
footprint and ensuring that minimum safe quantity or rock is used; and,
conventional overtrawl survey methods, in agreement with OPRED and fishing bodies.
6.1.7 Residual Impact

Decommissioning activities within the Banff and Kyle Fields will result in temporary direct and indirect
disturbance to the seabed. Temporary direct disturbance has the potential to impact approximately 0.18 km2
of seabed. Temporary indirect disturbance has the potential to impact approximately 0. 4 km2. There will be a
0.028 km2 area of permanent disturbance as a result of rock placement. These are considered highly
conservative estimations of the likely impact of the proposed decommissioning activities, as the buffers added
to the structures are likely to overestimate the range of impact generated by various removal methods.
Surveys have identified the OSPAR threatened or declining habitat ‘Seapen and burrowing megafauna
communities' within the Banff and Kyle Fields (Fugro, 2020a, 2020b). The general benthos and the species
associated with the OSPAR habitat specifically are likely to have some natural resilience to increased
sedimentation, if not to abrasion associated with direct disturbance. Considering the nature of the removal of
the subsea structures from the seabed, the opportunity for crushing or physical damage to seapens is minimal.
Furthermore, taking into account the mitigation measures described above (Section 6.1.6), this should ensure
that the area of impact will be as small as practicably possible. Given the very small area of direct and indirect
impact predicted to be generated by the proposed decommissioning, the activities are not likely to negatively
affect the seabed and benthos.
The EUNIS habitat complex A5.27 ‘Deep circalittoral sand’ covers approximately 150,506 km 2 of the North
Sea (NMPi, 2020), as such, the small area of disturbance modelled for the proposed decommissioning
(including both temporary and permanent direct impacts) may impact only a very small proportion (0.0001%)
of this habitat. Therefore, given the widespread nature of this substrate, the decommissioning will not affect a
significant proportion of this seabed. Impacts will mostly be temporary in duration and the bioturbation
observed in the surveys (Fugro, 2020a, 2020b and 2020c) suggests that sediment disturbance is naturally
occurring in the area to some degree.
The East of Gannet and Montrose Fields NCMPA is designated for deep-sea muds and ocean quahog
aggregations. While ocean quahog are not found in the vicinity of the Banff and Kyle Fields, the activities may
overlap with the deep-sea mud habitat (though survey evidence does not indicate the presence of deep-sea
mud at any of the sample locations; Fugro, 2020). Overall, the proposed decommissioning activities are
expected to have both a permanent and temporary impact on the site, covering an area of 0.0044 km2 and
0.0016 km2 respectively. The area of rock placement equates to 0.0003% of the NCMPA. Considering the
highly localised temporary nature of the activities and the mitigation measures outlined above, the habitat,
though sensitive, is not likely to be affected significantly by the decommissioning.
Based on the anticipated localised and temporary nature of the disturbance, the proposed decommissioning
of the Banff and Kyle Fields will have a negligible impact on seabed receptors.

6.2 Physical Presence of Infrastructure Decommissioned in situ in Relation to Other

Sea Users
6.2.1 Sources of Potential Impacts

The decommissioning of the Banff and Kyle Fields has the potential to impact on other users of the offshore
environment. In relation to the decommissioning of the Banff and Kyle Fields, the physical presence of subsea
infrastructure decommissioned in situ poses a potential snagging risk for commercial fisheries.
6.2.1.1 Physical presence of subsea infrastructure decommissioned in situ posing a potential
snagging risk
The long-term presence of subsea infrastructure decommissioned in situ has the potential to interfere with
other sea users. In particular, exposures or free-spans associated with infrastructure decommissioned in situ
which may arise during initial decommissioning and long-term degradation, may present a snagging risk to
some fisheries. In addition to the physical presence of the pipelines / umbilicals decommissioned in situ,
seabed depressions, local rock placement, mattresses and grout bags also increase the potential for
interaction with fishing gear. Demersal fishing gears which interact with the seabed are vulnerable to snagging.
Snagging may lead to the loss or damage of catch or fishing gear and may result in vessel destabilisation in
extreme circumstances. Generally, interactions between oil and gas infrastructure and fishing gear are most
prevalent in the muddy Northern North Sea (NNS) where the proportion of demersal fishing is relatively high
(Rouse, Hayes and Wilding, 2018), as opposed to the CNS where the Banff and Kyle Fields are located.
6.2.2 Effects on Sensitive Receptors

Annual fishing effort in the Banff and Kyle area (ICES rectangles 42F1 and 43F1) is variable. In rectangle
42F1 effort is consistently higher; in 2019 there were 251 days of effort compared to 28 days in rectangle 43F1
(Table 3-3 and Table 3-4). The targeted species type also differs between rectangles; in 43F1 demersal catch
contributes the most whereas in 42F1 shellfish dominate. Demersal catch includes trawl gears which interact
with the seabed and increase snag risk. Shellfish fisheries are associated with a more passive gear effort,
limiting contact with the seabed and any potential snag risks.
On review of demersal trawling activity in the North Sea, Rouse et al. (2017) found that a low percentage
(0.93%) of demersal trawling trips specifically targeted oil and gas pipelines compared with surrounding areas.
The disused pipeline from Kyle South to the Curlew Field (PL1798 and associated umbilical PL1800)
experiences some increased fishing compared to other Banff and Kyle Field pipelines (Figure 6-2), but the
number of trawl passes is still relatively low (19-24 trawl passes on average between 2007 and 2015; Figure
6-2). This corresponds to VMS data which highlights two areas of Nephrops activity on either side of the
pipeline (Figure 3-7) between which trawl vessels could be moving. In the middle of the disused pipeline
(where it experiences higher trawling intensity), no exposures were observed despite this ongoing activity
(Appendix E).

Figure 6-2 Traw ling across the Banff and Kyle pipelines in relation to areas of exposure
The other pipelines within the Banff and Kyle Fields experience significantly less fishing, possibly due to the
Fields’ proximity to the East of Gannet and Montrose Fields NCMPA, though fishing is not prohibited within the
area. More likely the sandier sediment within the Banff Field is less productive for commercial fisheries which,
with the focus in ICES rectangle 42F1 being shellfish, find the habitat around the Kyle Field more profitable.
The VMS fisheries data highlights fishing hotspots none of which come close to the Banff and Kyle Field
pipelines (Figure 3-7).

There are no FishSafe reportable spans within the Banff and Kyle Fields. There are 23 exposures along five
pipelines within the Banff and Kyle Fields totalling a length of 345 m. These exposures are located in clusters
towards the ends of the infield pipelines (shown in yellow on Figure 6-2) and coincide with areas of low trawling
intensity. All of these exposures will be remediated as appropriate using rock placement. Due to the water
depth and nature of the environment within the Fields it is unlikely that any exposures will move or continue to
grow as in a more mobile dynamic environment. Any potential changes in burial status of either pipeline
resulting in legacy impacts to commercial fisheries due to its degradation over time will be managed through
continued monitoring and communication with relevant users of the sea, as detailed in Section 6.2.4 below.
Overall, the region experiences low fishing activity and effort. In the areas along the discussed Kyle South to
Curlew pipeline where trawling intensity is slightly higher, the pipeline is stably buried to a suitable depth.
There are some exposures which will be remediated however they coincide with an area little used by
commercial fisheries. Overtrawlable rock remediation over these exposures will ensure any snag risk is
reduced. Therefore, the decommissioning activities will only reduce the potential for snagging events to occur
along a section of pipeline within an area which attracts little commercial activity regardless. Therefore,
snagging risks associated with the decommissioning of the pipelines in situ is minimal.
6.2.3 Cumulative and Transboundary Impacts

The Banff and Kyle Fields are located approximately 65 km and 73 km from the UK / Norway border
respectively. The most recent AIS vessel track data does not show much fishing vessel movement between
the UKCS and Norway. As such, the Fields are not likely to experience particularly high levels of fishing by
foreign vessels, though it may be marginally higher when compared to other nearshore regions of the UKCS.
Activity by fishing fleets of several non-UK nationalities may be recorded throughout the waters surrounding
the Banff and Kyle Fields; the most common of which are likely to be Norwegian, Danish and French vessels
which predominantly target blue whiting and mackerel (MMO, 2020).
In the wake of the decommissioning activities pipeline exposures will be remediated and the seabed will be
left in a safe overtrawlable condition, so no impacts to any UK and / or foreign fishing fleets are expected to
result from the proposed activities.
There are no other similar activities known to be occurring in the nearby area within the same timeframe (for
a schedule of activities see Section 2.4), therefore there are not likely to be any snagging-related cumulative
impacts on commercial fisheries resulting from activities coinciding with the decommissioning. This includes
activities covered by DP 1 – none of the other proposed activities discussed or permitted outwith this EA will
generate potential snag risk.
6.2.4 Mitigation Measures

A number of mitigation measures will be employed to reduce the impact on other sea users:
 The Banff and Kyle Fields’ subsea infrastructure is currently shown on Admiralty Charts , the FishSafe
system and the OGA Infrastructure data systems (OGA Open Data). Once decommissioning activities are
complete, updated information (i.e. which infrastructure remains in situ and which has been removed) will
be made available to allow the Admiralty Charts and the FishSafe system to be updated;
 Any exposures / cut flowline ends will undergo rock placement to ensure they are overtrawlable to active
fishing gears;
 Any objects dropped during decommissioning activities will be removed from the seabed where
appropriate;
 CNRI will monitor the seabed to assess any seabed depressions which may present a snag risk within the
Banff Field and are currently undertaking studies to determine the most appropriate method of remediation.
The survey results will be used in discussion with OPRED prior to the commencement of any intervention;
conventional overtrawl survey methods. Where there is evidence of residual snagging hazards (e.g. any

spans, berms, dropped objects, etc.), then intervention in the form of overtrawling to re-level the seabed
or the addition of rock placement will be discussed with OPRED, and implemented as appropriate; and
 CNRI recognise their commitment to monitor any infrastructure decommissioned in situ and therefore
intend to set up arrangements to undertake post-decommissioning monitoring. The frequency of the
monitoring that will be required will be agreed with OPRED and future monitoring will be determined
through a risk-based approach established from the findings from each subsequent survey. During the
period over which monitoring is required, the burial status of the infrastructure decommissioned in situ
would be reviewed and any necessary remedial action undertaken to ensure it does not pose a risk to
other sea users.
6.2.5 Residual Impact

The decommissioning of pipelines in situ should not pose an increased risk of snagging. All pipelines in the
Banff and Kyle Fields are considered suitably buried. The disused pipelines from Kyle South to Curlew has
two exposures along it at either end. These will be remediated as appropriate during the decommissioning.
These exposures coincide with areas where fishing effort and intensity are low. Therefore, in areas where
snagging has the greatest potential to occur there is little chance of interaction with fishing gear. The mooring
line trenches associated with the former location of the FPSO and any other seabed depressions will also be
remediated to mitigate against snag risk. While the method of remediation has not yet been determined, the
planned study will advise the appropriate method of remediation thereby ensuring the seabed is left safe and
unobstructed.
In the wider regional context, the waters in which the Banff and Kyle Fields and associated pipelines are
located experience overall low fishing effort, based on available fishing data. Foreign fleets are unlikely to
depend on the area significantly.
When accounting for the mitigation measures which will be implemented, and the fact that exposures will be
remediated appropriately during decommissioning, the potential for future snagging events is completely
reduced. Overall, the decommissioning of pipelines in situ is not anticipated to negatively impact commercial
fisheries.

7 CONCLUSIONS
Following detailed review of the proposed decommissioning activities, the environmental sensitivities
characteristic of the Banff and Kyle area, industry experience with decommissioning activities, and
consideration of stakeholder concerns, it was determined that potential project-related impacts to the seabed,
and commercial fisheries required further consideration
The Banff and Kyle infrastructure is located over 190 km offshore in the CNS, remote from coastal sensitivities
and overlapping slightly with the East of Gannet and Montrose Fields NCMPA, which is designated for the
protection of ocean quahog aggregations and deep-sea muds.
Decommissioning activities within the Banff and Kyle Fields will result in temporary direct and indirect
disturbance to the seabed (Section 6.1). Temporary direct disturbance has the potential to impact
approximately 0.18 km2 of seabed. Temporary indirect disturbance has the potential to impact approximately
0.4 km2 of seabed. Rock remediation activities will impact an area of approximately 0.028 km2. The activities
within the NCMPA which relate to rock placement will affect and area of 0.0044 km2. These activities have
the potential to cause minor discernible change to the baseline of existing benthic receptors within and outside
of the NCMPA. A further 0.012 km2 will be affected by temporary disturbance. However, considering the
highly localised temporary nature of the activities and the mitigation measures outlined, the habitat, though
sensitive, is not likely to be affected significantly by the decommissioning. Overall, only a fraction of the
NCMPA will be affected (0.0003%). The Conservation Objectives of the site intend to maintain the site in a
favourable condition, or otherwise improve it. As the area of impact within the site will be so minor, there is no
foreseeable opportunity for the activities to impact the condition of the site as a whole. Based on the
anticipated localised and temporary nature of the disturbance, the proposed decommissioning of the Banff and
Kyle Fields will have a negligible impact on seabed receptors.
Activities with the potential to impact upon commercial fisheries were limited to the possible legacy impacts
from the decommissioning of pipelines and associated protection materials in situ (Section 6.2). Such impacts
are restricted to commercial fisheries which make active contact with the seabed, such as those which operate
bottom trawl or dredging gears. All pipelines in the Banff and Kyle Fields are considered suitably buried and
all exposures or seabed depressions will be remediated. Recent trawling data indicates that areas of pipeline
exposure (and where remediation efforts will be focussed) do not coincide with high-intensity trawling routes.
In the wider regional context, the waters in which the Banff and Kyle Fields and ass ociated pipelines are
located experience overall low fishing effort, based on available fishing data. Foreign fleets are unlikely to
depend on the area. Based on these observations, coupled with mitigation measures which include focussed
overtrawl surveys (if required) and monitoring for exposures, impacts to commercial fisheries from snagging
risk from the decommissioning of the Banff and Kyle infrastructure are deemed negligible.
Finally, this EA has considered the objectives and marine planning policies of the NMP across the range of
policy topics including biodiversity, natural heritage, cumulative impacts and the oil and gas sector. CNRI
consider that the proposed decommissioning activities are in alignment with these objectives and policies.
Based on the findings of this EA, including the identification and subsequent application of appropriate
mitigation measures and Project management according to CNRI HSE Policies and Environmental
Management Systems (EMS), it is considered that the proposed Banff and Kyle decommissioning activities do
not pose any threat of significant impact to environmental or societal receptors within the UKCS or
internationally.

8 REFERENCES
Aires, C., Gonzlez-Irusta, J. M. & Watret, R., (2014). Scottish Marine and Freshwater Science Report, Vol 5
No 10, Updating Fisheries Sensitivity Maps in British Waters, Available online at
http://www.scotland.gov.uk/Publications/2014/12/3334
BEIS (2018). Decommissioning of Offshore Oil and Gas Installations and Pipelines. Available at:
https://www.gov.uk/guidance/oil-and-gas-decommissioning-of-offshore-installations-and-pipelines [Accessed
16.09.2020].
CNRI (2020). Banff and Kyle Fields Decommissionign Programmes for FPSO and FSO Float Off (Doc no:
P0009-CNR-EN-REP-00007)
Coull, K., Johnstone, R. & Rogers, S. (1998). Fisheries Sensitivity Maps in British Waters, Published and
distributed by UKOOA Ltd. Available online at https://www.cefas.co.uk/media/52612/sensi_maps.pdf
DECC (2016). UK Offshore Energy Strategic Environmental Assessment 3. UK offshore waters and territorial
waters of England and Wales. Available at https://www.gov.uk/government/consultations/ukoffshore-energy-
strategic-environmental-assessment-3-oesea3 [Accessed 01.09.2020].
Decom North Sea (2017). Environmental Appraisal Guidelines: Offshore Oil and Gas Decommissioning.
Available at: https://decomnorthsea.com/about-dns/projects-update/environmental-appraisalguidelines
[Accessed 16.09.2020].
Deecke, V.B., Slater, P.J.B. and Ford, J.K.B. (2002). Selective habituation shapes acoustic predator
recognition in harbour seals. Nature, 420, 171-173.
Duncan A. J. & McCauley R.D. (2009). Review of the L. Huson and Associates Report: Underwater Sound
Propagation Study – Blasting for Hay Point Coal Terminal Berth 3. Curtin University of Technology, Centre for
Marine Science and Technology, Project CMST 849, Report No. C2009-35.
Ellis, J.R., Milligan, S., Readdy, L., South, A., Taylor, N. & Brown, M. (2012). Mapping the spawning and
nursery grounds of selected fish for spatial planning. Report to the Department of Environment, Food and
Rural Affairs from Cefas. Defra Contract No. MB5301, Available online at
https://www.cefas.co.uk/publications/techrep/TechRep147.pdf
EMODnet (2019). Seabed Habitats Mapper. Available at: https://www.emodnet-seabedhabitats.eu/access-
data/launch-map-viewer/ [Accessed 31.08.2020]
FAO (2019). Fishing gear types – beam trawls. Available at http://www.seafish.org/geardb/gear/beamtrawl/
[Accessed 30/11/2020].
Finneran J.J., Carder D.A., Schlundt C.E. and Ridgway S.H. (2005). Temporary threshold shift in bottlenose
dolphins (Tursiops truncatus) exposed to mid-frequency tones. Journal of the Acoustical Society of America,
118(4), 2696-2705.
Fugro (2020a). Banff Habitat Assessment Report, CTR011431-FSS-EN-REP-00001 B1
Fugro (2020b). Kyle Habitat Assessment Report, CTR011431-FSS-EN-REP-00002 B1
Fugro (2020c). Environmental Pre-Decommissioning Report: Banff and Kyle, CTR011431-FSS-EN-REP-
00004 A1
Hammond, P.S, Lacey, C., Gilles, A., Viquerat, S., Börjesson, P., Herr, H., Macleod, K., Ridoux, V., Santos,
M.B., Scheidat, M., Teilmann J., Vingada, J. and Øien, N. (2017). Estimates of cetacean abundance in
European Atlantic waters in summer 2016 from the SCANS-III aerial and shipboard surveys. Available at:
https://synergy.st-andrews.ac.uk/scans3/files/2017/05/SCANS-III-design-based-estimates-2017-05-12-
finalrevised.pdf [Accessed 31.08.2020].
Hill, J.M., Tyler-Walters, H. & Garrard, S. L. 2020. Seapens and burrowing megafauna in circalittoral fine mud.
In Tyler-Walters H. and Hiscock K. (eds) Marine Life Information Network: Biology and Sensitivity Key
Information Reviews, [on-line]. Plymouth: Marine Biological Association of the United Kingdom. [cited 06-11-
2020]. Available from: https://www.marlin.ac.uk/habitat/detail/131

HSE (Health and Safety Executive) (1997). The abandonment of offshore pipelines: Methods and procedures
for abandonment. Offshore technology report. HSE Books, Norwich. ISBN -7176-1421-2.
JNCC (2010). The protection of marine European Protected Species from injury and disturbance – Guidance
for the marine area in England and Wales and the UK offshore marine area.
JNCC (2014a). JNCC clarifications on the habitat definitions of two habitat Features of Conservation
Importance: Mud habitats in deep water, and; Sea-pen and burrowing megafauna communities. Available
online at: http://data.jncc.gov.uk/data/91e7f80a-5693-4b8c-8901-11f16e663a12/3-AdviceDocument-
MudHabitats-Seapen-definitions-v1.0.pdf [Accessed on 03.09.2020]
JNCC (2014b). Scottish MPA Project: Data Confidence Assessment for East of Gannet and Montrose Fields
Nature Conservation MPA. Available at: http://data.jncc.gov.uk/data/18a1c6a2-7dc3-4ee5-b6fd-
09f756d2d30c/EGM-2-DataConfidenceAssessment-v5.0.pdf [Accessed 31.08.2020]
JNCC (2017). East of Gannet and Montrose Fields MPA. Available at: https://jncc.gov.uk/our-work/east-of-
gannet-and-montrose-fields-mpa [Accessed 31.08.2020]
JNCC (2018a). Conservation Objectives for East of Gannet and Montrose Fields NCMPA. Available at:
http://data.jncc.gov.uk/data/7d1e751a-e082-405b-aad9-51eeaf53dd67/EGM-2-ConservationObjectives-
v1.0.pdf [Accessed 31.08.2020]
JNCC (2018b). East of Gannet and Montrose Fields MPA: Advice on Operations. Available online at:
https://data.jncc.gov.uk/data/7d1e751a-e082-405b-aad9-51eeaf53dd67/EGM-5-AdviceOnOperations-
v1.0.xlsx [Accessed 06.11.20]
JNCC (2020). Evidence base for application of Acoustic Deterrent Devices (ADDs) as marine mammal
mitigation, Report No 615.
Jones, E. L., McConnell, B. J., Smout, S. C., Hammond, P. S., Duck, C. D., Morris, C., Thompson, D., Russell,
D.J.F., Vincent, C., Cronin, M., Sharples, R. J. & Matthiopoulos, J., 2015. Patterns of space use in sympatric
marine colonial predators reveals scales of spatial partitioning. Marine Ecology Progress Series, vol 534, pp.
235-249. DOI: 10.3354/meps11370. Available online at https://research-repository.st-
andrews.ac.uk/bitstream/handle/10023/9386/Jones_2015_MEPS_Patterns_AM.pdf?sequence=1&isAllowed
=y [Accessed 30/09/2020].
Jones, E., McConnell, B., Sparling, C., Matthiopoulos, J. (2013). Marine Mammal Scientific Support Research
Programme MMSS/001/11: Grey and harbour seal density maps. Available at: http://www.smru.st-
andrews.ac.uk/files/2015/10/MR5_Seal_density_maps.pdf [Accessed 01.09.2020]
Kennish, M. J. (1997). Pollution Impacts on Marine Biotic Communities. CRC Press LLC, USA, ISBN 0-8493-
8428-1
Kober, K., Webb, A., Win, I., Lewis, M., O’Brien, S., Wilson, J. L., Ried, B. J., (2010). An analysis of the
numbers and distribution of seabirds within the British Fishery Limit aimed at identifying areas that qualify as
possible marine SPAs. ISSN; 0963-8091. JNCC report No.431.
MMO (2020). UK sea fisheries annual statistics report 2019. Available online at
https://www.gov.uk/government/statistics/uk-sea-fisheries-annual-statistics-report-2019 [Accessed
28/09/2020].
MPE (Ministry of Petroleum and Energy) (1999). The Final Disposal of Disused Pipelines and Cables.
Summary of the Findings of a Norwegian Assessment Programme. Oslo, December, 1999.
NMFS (2005). National Marine Fisheries Service Guidance for Marine Mammal Acoustic Technical Guidance.
NMPi (National Marine Plan Interactive) (2020). National Marine Plan Interactive. Available at:
http://www.gov.scot/Topics/marine/seamanagement/nmpihome [Accessed 01/10/2020].
North Sea Link (2020). Statnett and National Grid North Sea Link. Available at: https://www.northsealink.com/
[Accessed 19.09.2020]
OGUK (2013). Long term Degradation of Offshore Structures and Pipelines Decommissioned and left in situ,
Oil and Gas UK. February 2013.

Oil and Gas Authority (2016). Information of levels of shipping activity. 29th Offshore Licensing Round
information and resources. Available online at:
https://www.ogauthority.co.uk/media/1419/29r_shipping_density_table.pdf [Accessed 21.09.2020].
Oil and Gas Authority (2019). Other Regulatory Issues. 32 nd Licensing Round information and Resources.
Available online at: https://www.ogauthority.co.uk/media/6047/other-regulatory-issues_sept-05-2019.pdf
[Accessed 21.09.2020].
Oil and Gas Authority (2021). Net Zero Stewardship Expectation 11. Available online at:
https://www.ogauthority.co.uk/media/7184/se11_net-zero.pdf
Reid, J., Evans, P. & Northridge, S. (2003). An atlas of cetacean distribution on the northwest European
Continental Shelf, Joint Nature Conservation Committee: Peterborough.
Rouse, S., Hayes, P. and Wilding, T. (2018). Commercial fisheries losses arising from interactions with
offshore pipelines and other oil and gas infrastructure and activities. ICES Journal of Marine Science, 77(3),
pp.1148-1156.
Rouse, S., Kafas, A., Catarino, R., and Hayes, P. (2017). Commercial fisheries interactions with oil and gas
pipelines in the North Sea: considerations for decommissioning, ICES Journal of Marine Science, 75(1): 79–
286.
Russell, D. F., Jones, E. L., Morris, C. D. (2017). Updated Seal Usage Maps: The Estimated at -sea Distribution
of Grey and Harbour Seals, Scottish Marine and Freshwater Science Report Vol 8 No 25. Available at:
https://data.marine.gov.scot/dataset/updated-seal-usage-maps-estimated-sea-distribution-grey-and-harbour-
seals [Accessed 01.09.2020]
SCOS, 2017. Scientific advice on matters related to the management of seal populations: 2017. Available at:
http://www.smru.st-andrews.ac.uk/files/2018/01/SCOS-2017.pdf [Accessed 30/09/2020].
Scottish Government (2019). Scottish Sea Fisheries Statistics, 2019, Scottish Government. Available online
at http://www.gov.scot/Topics/marine/marine-environment/species/fish
SMRU, 2011. Utilisation of space by grey and harbour seals in the Pentland Firth and Orkney waters, Scottish
Natural Heritage Commissioned Report No. 441.
SNH (2017). Buchan Ness to Collieston Coast SPA. Available at: https://sitelink.nature.scot/site/8473
[Accessed 03.09.2020]
Tyler-Walters, H., James, B., Carruthers, M. (eds.), Wilding, C., Durkin, O., Lacey, C., Philpott, E., Adams, L.,
Chaniotis, P.D., Wilkes, P.T.V., Seeley, R., Neilly, M., Dargie, J. & Crawford-Avis, O.T (2016). Descriptions of
Scottish Priority Marine Features (PMFs). Scottish Natural Heritage Commissioned Report No. 406.
Webb, A., Elgie, M., Irwin, C., Pollock, C. & Barton, C. (2016). Sensitivity of offshore seabird concentrations
to oil pollution around the United Kingdom: Report to Oil & Gas UK. Document No HP00061701. Available
online at http://jncc.defra.gov.uk/page-7373.
Yelverton, J. T., Richmond, D. R., Fletcher, E. R., & Jones, R. K. (1973). Safe distances from underwater
explosions for mammals and birds. DNA 3114T, Rep. From Lovelace Foundation for Medical Educ. And Res.,
Alburquerque, NM, for Defence Nuclear Agency, Washington, DC, 67 p, NTIS AD-766952.
Yelverton, J. T., & Richmond, D. R. (1981). Underwater explosion damage risk criteria for fish, birds, and
mammals. The Journal of the Acoustical Society of America, 70(S1), S84-S84.

APPENDIX A ITEM INVENTORY

Appendix A.1 Group 1 Pipelines
Pipeline ID Description OD (inches) Length (km )
PL1546 10" Banff Oil Production Pipeline (P2), Manifold to Riser Base 10 1.546
PL1547 10" Banff Oil Production Pipeline (PI), Manifold to Riser Base 10 1.546
PL1548 10" Banff Water Injection Pipeline, Riser Base to Manifold 10 1715
PL1550 12" Banff Oil Export Pipeline, Tie-in Spool to 12" Flow line 12 1 248
PL1660 8" Kyle Oil Production Pipeline, North Kyle DC to Riser Base 8 12.023
PL1797 8" Kyle Oil Production Pipeline, Kyle North Well to Kyle North 8 3.370
Flow line
PL1798 Tie-in Flange 12 17.383
PL2388 12" Curlew Production Pipeline, Kyle South 12" Tee Structure to 4 3.289

PL2052 6" Banff Gas Lift / Injection Flow line, Gas Lift / Injection Riser 6 1.800
base to Gas Lift / Injection Manifold
PL1552 1 & 2 Umbilical (Hydraulic / Chemical), FPSO TUTU to Banff 4.75 1.990
Manifold
PL1553, Umbilical (Hydraulic / Chemical), DUTA to Banff Manifold 4.85 1.625
PL1554.1-7
PC 1661.1-22 Kyle Umbilical (Electrical / Hydraulic / Chemical), DUTA to 5.4 1.926
Well K14
PL3117 Kyle Umbilical (Electrical / Chemical), Kyle SSIV to North Kyle 12.292 12.292
SAM
PL1799.1-8 Main Kyle Umbilical, Kyle North SAM to Kyle South SDU 5.4 3.607
Appendix A.3 Group 3 Flexible Flowline

PLU4522 Pow er Umbilical 3 1.6

PLU3106 Banff gas export SSIV umbilical 3 0.536

PL1549 6” Banff Gas Export Pipeline, API Transition Spool to CATS 6 6.268
Tie-in
PL2387 4” Kyle Gas Lift Pipeline, Banff Gas Lift / Injection Manifold to 4 10.252
Kyle North Gas Lift / Choke Manifold

Appendix A.5 Structures
Description Location Length (m ) Width (m ) Height (m )
Banff Gas Lift / Injection Manifold 18 14 4.775

Banff Production Manifold 18 16 5.178
Gas Lift / Choke Manifold 13 11 3.65
Banff Dynamic Umbilical Termination Unit (DUTU)
7.5 5.5 2.937
Structure
P1 Production Riser Base 8.65 4.5 4.3
P2 Production Riser Base 8.65 4.5 4.3
Gas Lift / Injection Riser Base 8.7 4.5 4.3
Oil Export Tether Base 7 7 2.9
Oil Export STL Tether Base 4 3 1.4
Suction Base (SAL Anchor Base) 9 9 16.7
Pipeline End Manifold (PLEM) Tee 3.1 3 1.7
Banff Umbilical Tether Base 7 7 2.9
Gas Export SSIV Structure 10 5.5 3.9
Gas Export Tether Base 6 6 3.2
Banff Umbilical Tether Base Anode Skid A 1.9 1.5 0.7
Banff
Banff Umbilical Tether Base Anode Skid B 1.9 1.5 0.7
Gas Export Tether Base Anode Skid A 1.9 1.5 0.7
Gas Export Tether Base Anode Skid B 1.9 1.5 0.7
Gas Export SSIV Anode Skid 1.9 1.5 0.7
Oil Export Riser Base Structure Anode Skid A 1.9 1.5 0.7
Oil Export Riser Base Structure Anode Skid B 1.9 1.5 0.7
PLEM Tee Anode Skid 0.75 0.5 0.2
Abandoned Guide Base 9.4 9.4 3.1
Abandoned Guide Base 2.8 2.8 3
Abandoned Guide Base 3 3 3.4
Abandoned Guide Base 3 3 3.4
Xmas Tree w ith Guide Base Well B1 5.3 5.3 5.2
SDU / SAM Structure 9 8 1.9
North Drill Centre Valve Structure 10 8 2.4
Kyle SSIV Structure 6 7.5 3.2
Kyle Production Riser Base 8 8 3.2
Kyle Umbilical Riser Base Kyle North 8 8 3.2
Disconnected Structure (Old SDU / SAM Structure) 7.6 6.8 1.8
Umbilical Tee c/w Protective Cover 6.2 3 1.3
Abandoned Guide Base 2.8 2.8 3
Xmas Tree w ith Guide Base Well K14 5.3 5.3 5.2

Abandoned Umbilical Tee Connector 6.2 4.3 1.3

Banff to Kyle North Umbilical Wet Splice 3 1.2 0.8
Kyle North to Kyle South Umbilical Wet Splice 2.6 1.2 0.6
12" Tee Structure 11.8 8.7 2.2
South Drill Centre Valve Structure (8" Tee Structure) 10 8 2.4
Kyle South
Curlew Umbilical DUTU 3 1.3 1.2
Appendix A.6 Group 8 STL Piles
Subsea installations Num ber Size (m ) Weight (Te) Com m ents / Status
Anchor pile has approximately 8 m of chain in

30 m x 1.83 m 102 Te 60% burial, exposed at the pile w ith no trench
visible
Anchor pile has chain bundle approximately
30 m x 1.83 m 102 Te 10 m from pile position. Chain to pile and pile
4 all in full burial.
(Type C) Anchor pile has small chain bundle
30 m x 1.83 m 102 Te approximately 8 m from the pile suspected
position. Chain to pile and pile all in full burial.
ML4 Anchor pile has approximately 4 m of
30 m x 1.83 m 102 Te chain in 50% burial 4 m from the estimated pile
position. The chain to pile all in full burial.
STL Mooring Piles
ML5 Anchor pile is visible approximately 30
cm above seabed- 9 m from the pile there is
24 m x 1.83 m 80 Te
half a link of chain exposed- all other chain in
3
burial.
(Type B)
Anchor pile is not visible nor is the chain- all in
24 m x 1.83 m 80 Te
full burial.
Anchor pile is protruding approximately 30 cm
24 m x 1.83 m 80 Te
above seabed- all chain in full burial.
ML8 anchor pile is exposed protruding
1 approximately 20 cm above the seabed- there
28 m x 1.83 m 93 Te
(Type A) is approximately 4 m of chain in 20% burial
next to the pile.
Appendix A.7 Spools, Jumpers and SSIVs

Pipeline No. Dia. Length
Field Description
(as per PWA) (in) (km )
Banff Banff Production P2 PL1546 10” / 8” 1.759
Banff Oil Production flexible Jumper PL1546(J) B5 8” 0.020
Banff Banff Production P1 PL1547 10” 1.740
Banff Banff Gas Lift / Injection PL1548 8” 0.001
Banff Banff Water Injection PL1548 10" 1.687


Field Description
Banff Banff Gas Export PL1549 6” 6.578
Banff Banff Gas Export (redundant section) PL1549A 6” 0.150
Banff Banff Oil Export PL1550 12” 1.920
Banff Banff Oil Export, SAL (redundant section) PL1550A 12” 0.324
Kyle Kyle Production PL1660 8” 12.023
Kyle Kyle Production (redundant section) PL1660A 8” 0.400
Kyle Kyle EHC Umbilical PL1661.1-.22 5.4” 12.033
Kyle Kyle K13 Production PL1797 8” 3.370
Kyle Kyle K12 Production (Curlew pipeline) PL1798 12” 16.975
Kyle Kyle K12 Production PL1798A 12”/8” 0.115
Kyle Kyle South EHC umbilical PL1799.1-.19 5.4” 3.548
Kyle Kyle K13 Umbilical (redundant) PL1799A 3.85” 0.143
Kyle Kyle K12 umbilical PL1800A 4” 0.030
Kyle Kyle K14 Production PL1887 11” 0.050
Kyle Kyle K15 Production PL1952(J) 10.75” 0.056
Kyle Kyle K15 umbilical PL1953(J) 11” 0.075
Banff Banff Gas Lift / Injection PL2052 6” 1.842
Banff Banff Gas Lift / Injection PL2052JB1 2” 0.039
Banff Banff Production PL2053 6” 0.039
Kyle Kyle North chemical umbilical PL2189 1.4” 0.045
Kyle Kyle North Gas Lift PL2387 4” 10.252
Kyle Kyle North gas lift K13 PL2387JK13 2” 0.060
Kyle Kyle North gas lift K14a PL2387JK14a 2” 0.058
Kyle Kyle South Gas Lift PL2388 4” 3.289
Kyle Kyle South gas lift K12z PL2388JK12z 2” 0.051
Kyle Kyle South gas lift K15 PL2388JK15 2” 0.040
Banff Banff B1 control umbilical PL4987 2” 0.039
Banff Banff Chemical Injection umbilical PLU1552 4.75” 1.750
Banff Banff Chemical Injection umbilical PLU1553 4.75” 1.625
Banff Banff Chemical Injection umbilical PLU1554.1-.7 4.75” 1.625
Kyle Kyle K14 umbilical (redundant) PLU1888 11” 0.045
Kyle Kyle K13 umbilical PLU2188 11” 0.154
Kyle Kyle North K13 control umbilical PLU2389 11” 0.083
Kyle Kyle North K14a control umbilical PLU2390 11” 0.083
Kyle Kyle North control umbilical PLU2391 11” 0.127
Kyle Kyle South K15 control umbilical PLU2392 11” 0.054
Kyle Kyle South control umbilical PLU2393 11” 0.095
Kyle Kyle South K12z control umbilical PLU2394 11” 0.086
Kyle Kyle North control umbilical PLU2520 6” 0.150
Banff Banff Control Umbilical PLU4522 3" 1.651


Field Description
Kyle Kyle South umbilical (Curlew ) PL1800 5.5" 17.300
Kyle Kyle umbilical PLU3117 4" 12.292
Banff Banff Oil Export (redundant section) PL5073 12" 0.07
Appendix A.8 Pipeline Structures
Description Location Length (m ) Width (m ) Height (m )
Banff Gas Lift SSIV Structure Banff 10 5.5 3.9

Banff Gas Export SSIV Structure Banff 8.7 8.3 3.4
Kyle Subsea Isolation Valve (SSIV) Structure Kyle South 6 7.5 3.2
Banff to Kyle North Umbilical Wet Splice Kyle North 3 1.2 0.8
Kyle North to Kyle South Umbilical Wet Splice Kyle North 2.6 1.2 0.6
Appendix A.9 Stabilisation Materials

Total Total
Stabilisation Feature Locations Exposed/Buried/Condition
Number weight (Te)
Latest survey information indicates
Concrete Mattresses 6 Various locations that there is a mixture of some
1,340 8,392 across pipeline mattresses are doubled up, rock
(6 m x 3 m x 0.15 m) infrastructure covered, shared w ith other pipelines
and multiple overlaps.
Concrete Mattresses 7 Various locations that there is a mixture of some
210 1,798 across pipeline mattresses are doubled up, rock
(6 m x 3 m x 0.3 m) infrastructure covered, shared w ith other pipelines
and multiple overlaps.
Various locations
that there is a mixture of some grout
Grout Bags (25 kg bags) 8 13,500 306.25 across pipeline
bags covered by mattresses and
infrastructure
some exposed.
6
Concrete mattresses are: 6 m x 3 m x 0.15 m (approximate mass of each mattress 6.7 Te)
7
Concrete mattresses are: 6 m x 3 m x 0.3 m (approximate mass of each mattress 8.3 Te)
8
The quantity of grout bags is an estimate as the as-built data is not explicit.

APPENDIX B CNRI POLICIES

Appendix B.1 CNRI Health & Safety Policy

Appendix B.2 CNRI Environmental Management Policy

APPENDIX C ENVID



APPENDIX D ENERGY AND EMISSIONS SUMMARY

Appendix D.1 Energy and emissions by project activity
Operations energy Operations
Planned activity
(GJ) CO2 (Te)
Offshore transportation 111,680.3 8,291.8

Onshore deconstruction 5,653.3 ND
Onshore transportation 38.9 2.8
Recycling of materials 21,979.5 2,310.0
New manufacture to replace recyclable materials 1,620.2 49.1
Total 140,972.1 10,653.6
Appendix D.2 Offshore transport energy and emissions
Total Duration (days)

Operations
Operations
Vessel type energy
CO2 (Te)
Mob / Wait on (GJ)
Transit Working
Demob Weather
Diving Support Vessel 1.5 1.17 15.25 3.05 14,445.7 1,072.5

Construction Support Vessel 19.75 12.92 45.81 8.72 55,100.0 4,091.0
Rock Vessel 4.6 3.0 13.0 2.20 11,257.7 835.8
Survey Vessel 6.0 3.0 33.0 3.6 30,876.8 2,292.5
Total 111680.3 8291.8

APPENDIX E PIPELINE EXPOSURES SUMMARY

Appendix E.1 Survey Assessment Summary Reports
Appendix E.1.1 PL1546

Pipeline / Umbilical
PL1546
Ident.
Pipeline / Umbilical Trenched & Buried, P2 10" Banff Oil Production
Description
Start Location Banff Production Manifold
End Location Riser Base
Survey Assessment Summary

Total
Survey
Qty. Exposure Lengths (m) Exposure
Year
Length (m)
2019 5 7.6 24.2 5.4 18.6 32.3 88.2
2017 3 7.5 22 0.7 30.0
2016 1 21.65 21.65
Notes:
The areas of span are located toward the ends of the pipeline.
Images:
PL1546 KP0.054 PL1546_KP1.494

PL1546_KP1.619 PL1546_KP1.693
Location Map

Video References
PL1546_KP0.05 PL1546_KP1.49 PL1546_KP1.58 PL1546_KP1.61 PL1546_KP1.69
2019 4 4 0 9 3
2017 PL1546_2017_1 PL1546_2017_2 PL1546_2017_3
2016 PL1546_2016_1 PL1546_2016_2


Pipeline / Umbilical Ident.
PL1547
Pipeline / Umbilical Trenched & Buried, P1 10" Banff Oil Production
Description
Start Location Banff Production Manifold

Total
Survey Exposure
Qty. Exposure Lengths (m)
Year Length
(m)
2019 4 7.78 3.61 10.6 55.2 22.0
2017 5 38 7.2 4.1 12 61 121.2
2016 5 65.3 8.7 11.4 61.3 4.4 151.1
Notes:
The largest exposure was a section of the pipeline that was covered in mattresses. Spans are due
to excavation works carried out.
Images:
VLCSNAP-2020-10-29 KP 0.06 VLCSNAP-2020-10-29 KP 1.5
Location Map

Video References
vlcsnap-2020- vlcsnap-2020-
2019
10-29 kp 0.06 10-29 kp 1.5
PL1547_2017 PL1547_2017 PL1547_2017 PL1547_2017 PL1547_2017
2017
_1 _2 _3 _4 _5
2015-039- 2015-038-
2016 2016_MATTR EXP_2016_PI EXP_2016_PI
ESS CS CS


PL1548
Pipeline / Umbilical Trenched & Buried, 10" Water Injection
Description (Disconnected)
Start Location Riser Base
End Location Banff Production Manifold

Total
Survey Exposure
Year Length
(m)
2019 8 18.9 20.9 11.1 7.7 3.9 20.2 19.1 101.9
2017
2016 5 6.53 19.02 20.12 9.79 12.49 67.9
Notes:
The largest exposure was a section of the pipeline that was covered in mattresses.
Images:
PL1548_21-07-46 PL1548_21-09-49
PL1548_21-12-34 PL1548_21-14-37

PL1548_21-53-18 PL1548_21-56-18
PL1548_21-56-47 PL1548_21-58-13
Location Map
The location of the pipeline was not available meaning it was not possible to plot the exposure
points.
Video References
PL1548_21- PL1548_21- PL1548_21-12- PL1548_2 PL1548_2
2019 07-46 09-49 34 1-14-37 PL1548_21-53-18 1-56-18
2017
PL1548_201 PL1548_2016 PL1548_2
2016 6_1 _2 PL1548_2016_3 016_4 PL1548_2016_5


PL1550
Pipeline / Umbilical Trenched & Buried 12" Banff Oil Export
Description
Start Location Tie-in Spool
End Location 12" Flexible Flowline

Total
Survey
Year
Length (m)
2019 6 14.32 4.03 67.66 3.20 11.66 11.05 111.91
2017
2016
2015 7 17.81 13.16 5.41 65.69 4.77 12.03 12.17 131.03
Notes:
The largest exposure was a section of the pipeline that was covered in mattresses.
Images:
PL1550_KP0.672-0.701 PL1550_KP0.701-0.768
PL1550_KP0.776-0.790

Location Map
The location of the pipeline was not available meaning it was not possible to plot the exposure points.
Video References
PL1550_KP0.672- PL1550_KP0.701- PL1550_KP0.768- PL1550_KP0.776-
2019 0.701 0.768 0.770 0.790
2017
2016
2015 PL1550_2015_1 PL1550_2015_2 PL1550_2015_3 PL1550_2015_4 PL1550_2015_5


PL1660
Pipeline / Umbilical Description Trenched & Rock Covered, Kyle 8" Production
Pipeline
Start Location North Kyle Drill Centre Tie-in Tee

Total
Survey
Year
Length (m)
2019 2 10 13 23.0
2017 3 10 10 11 31.0
2016
2015
Notes:
It is assumed that the exposures are the same, however, the video did not contain positional information
that could be cross referenced between the years.
Images:
2019-2015-007_SPA 2019-2015-015_SPA
Location Map

Video References
2019 - 2015 - 014 2019 - 2015 - 007 -
2019
and 015 SPA
2017 2017-2015-005 2017-2015-007
2016

Appendix E.1.6 PL1799.1-8

PL1799.1-8
Pipeline / Umbilical Trenched & Rock Covered, Main Kyle Umbilical
Description
Start Location Kyle North SDU/SAM
End Location Kyle South SDU

Total
Survey Exposure
Year Length
(m)
2019 1 0.6 13 0.6
2017 3
2016
2015
Notes:
Only a small section of pipeline could be seen.
Images:
No images available
Location Map
The location of the pipeline was not available meaning it was not possible to plot the exposure points.
Video References
2019
2017
2016


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BANFF & KYLE DECOMMISSIONING PROJECT

CNR Project Banff & Kyle Decommissioning

REPORT - BANFF AND KYLE DECOMMISSIONING

B1 ISSUED FOR INFORMATION 24/5/2021 KL PR PR SB

DISC. DISC. CNR

Rev Date Revision Details

Document Number: P0009-CNR-EN-REP-00015 Issue Date: 24/05/21

TERMS AND ABBREVIATIONS 6

Introduction and Background 9

2.1 Decision Making Context 21

3 ENVIRONMENTAL AND SOCIETAL BASELINE 35

Document Number: P0009-CNR-EN-REP-00015 Issue Date: 24/05/21

3.4 Sensitive Receptors 41

5 IMPACT ASSESSMENT SCREENING AND JUSTIFICATION 60

6.1 Disturbance to the Seabed 68

APPENDIX A ITEM INVENTORY 91

Appendix A.1 Group 1 Pipelines 91

Document Number: P0009-CNR-EN-REP-00015 Issue Date: 24/05/21

Appendix A.7 Spools, Jumpers and SSIVs 93

APPENDIX B CNRI POLICIES 96

Appendix B.1 CNRI Health & Safety Policy 96

APPENDIX D ENERGY AND EMISSIONS SUMMARY 101

Appendix D.1 Energy and emissions by project activity 101

APPENDIX E PIPELINE EXPOSURES SUMMARY 102

Appendix E.1 Survey Assessment Summary Reports 102

Document Number: P0009-CNR-EN-REP-00015 Issue Date: 24/05/21

TERMS AND ABBREVIATIONS

Document Number: P0009-CNR-EN-REP-00015 Issue Date: 24/05/21

Document Number: P0009-CNR-EN-REP-00015 Issue Date: 24/05/21

PWA Pipeline Works Agreement

Document Number: P0009-CNR-EN-REP-00015 Issue Date: 24/05/21

Figure 1-1 Location of the Banff and Kyle Fields

Document Number: P0009-CNR-EN-REP-00015 Issue Date: 24/05/21

Figure 1-2 Banff and Kyle Field illustration

Document Number: P0009-CNR-EN-REP-00015 Issue Date: 24/05/21

Document Number: P0009-CNR-EN-REP-00015 Issue Date: 24/05/21

Options for Decommissioning

CA Group Subsea Infrastructure Scoping Decommissioning Options Considered

Flexibles / Umbilicals Scoped in Option 2b: Reverse Reel w ithout De-Burial

Flexibles / Umbilicals, Scoped out Full Rem oval

5 Spools and Jumpers Scoped out Full Rem oval

Subsea Installations Scoped out Full Rem oval

7 Protection / Stabilisation Scoped out Full Rem oval

STL piles Scoped in Option 2c: Reverse Installation w ith De-Burial

Document Number: P0009-CNR-EN-REP-00015 Issue Date: 24/05/21

Environmental and Societal Sensitivities

Document Number: P0009-CNR-EN-REP-00015 Issue Date: 24/05/21

Other Sea Users

Document Number: P0009-CNR-EN-REP-00015 Issue Date: 24/05/21

Document Number: P0009-CNR-EN-REP-00015 Issue Date: 24/05/21

Document Number: P0009-CNR-EN-REP-00015 Issue Date: 24/05/21

Figure 1-1 Location of the Banff and Kyle Fields

Document Number: P0009-CNR-EN-REP-00015 Issue Date: 24/05/21

1.2 Regulatory Context

Document Number: P0009-CNR-EN-REP-00015 Issue Date: 24/05/21

Figure 1-2 Banff and Kyle Field illustration

Document Number: BFD399029-XDS-EN-REP-00002 Issue Date: 20/05/21

1.3 Scope and Structure

1.3.1 Scope of the Environmental Appraisal

1.3.2 Structure of the Environmental Appraisal