Last week Kirsty Macpherson and I attended the Offshore Renewable Energy Decommissioning Guidance event hosted by Marine Scotland.
This was a great opportunity for us to engage with key stakeholders within the sector, and share our experiences of working with clients to fulfil decommissioning obligations under project consents.
The event comes as Marine Scotland is consulting on its first draft guidance following the transfer of responsibility for considering offshore renewable energy decommissioning cases in Scottish waters from the UK Government to the Scottish Ministers.
While the aim is to minimise divergence between the two decommissioning regimes, there are a few key differences in Marine Scotland's proposed approach:
- Timing - Marine Scotland's proposals would require approved decommissioning programmes to be in place prior to construction, and initial draft programmes to be submitted around 18 months in advance. This is significantly earlier than has tended to be required under the UK Government's administration.
- Test Centres - The UK Government's approach is that test centres (like the European Marine Energy Centre in Orkney) are liable for the decommissioning of all tenant projects within their sites. Marine Scotland would instead put this responsibility on tenants and require individual decommissioning schemes.
- Financial Security - It is indicated that there will be greater focus on and scrutiny of the securities to be put in place and the financial modelling underpinning the wider renewables project.
Marine Scotland is keen to receive comments on all aspects of the decommissioning process - you can have your say here. The consultation is open until 16 March 2020 and we will keep you updated as the guidance progresses.