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Representation by UK Chamber of Shipping (UK Chamber of Shipping)

Date submitted
19 June 2024
Submitted by
Non-statutory organisations

The UK Chamber of Shipping is the trade association for the UK shipping industry, representing some 200 members, operating 900 vessels equalling 18 million GT in capacity, trading around the UK and globally. The Chamber represents the full breadth of the industry, including dry and wet trades, passenger transport (cruise & ferry), offshore supply and construction, towage, and specialist, as well as professional service providers with shipping interests. The Chamber fully supports the Government’s obligations to achieve Net Zero Carbon by 2050 and welcomes the development of offshore renewable energy to succeed in this obligation. The ports and shipping industries play an essential in enabling those targets to be achieved by providing bases and vessels for construction, operation & maintenance, and decommissioning. The Chamber also asserts that the planning process and framework must support the wider shipping industry through site selection which avoids or minimises disruption or economic loss to the shipping and navigation industries, with particular regard to approaches to ports and to strategic routes essential to regional, national and international trade, lifeline ferries, as stated within Paragraph 2.8.328 of NPS EN-3. The Chamber seeks to ensure navigational safety is upheld and that developments are appropriately positioned to enable existing and future commercial navigation to continue safely and efficiently. Shipping is the greenest form of cargo transport and proposed offshore renewable developments must take fully into consideration the routeing and operations of commercial shipping to enable this to continue. The Chamber has been closely involved in the planning process for Morgan OWF prior to DCO application, through Scoping, PEIR, Simulation Exercises with international scheduled Roll-on Roll-off and Passenger Ferry services, and Hazard Workshops in the development of the Navigational Risk Assessment. The Chamber found the development as initially presented is unacceptable on grounds of navigation safety in isolation and cumulatively, and has advocated for enhanced mitigation measures. The Chamber has welcomed constructive manner the Red Line Boundary (development area) has been amended to take in account of navigational safety concerns for national and international scheduled services, however asserts there remain ongoing concerns relating to deviation, scheduling and negative environmental impact upon the shipping industry from the revised boundaries, along with potential negative economic impact to island communities which need full consideration. The cumulative impact to the commercial shipping industry of Morgan OWF in addition to Mona and Morecambe which are entering the DCO process is unprecedented in its simultaneous nature. The Chamber therefore requests the opportunity to provide further representation in the area of navigational safety and impact upon commercial routeing at Examination where appropriate.