Proactima urges the Ministry of Petroleum and Energy to set higher requirements for HSE (Health, Safety, and Environment) in the pre-qualification process for offshore wind power.
In the realm of sustainability, Proactima hopes that the ministry will both include requirements in the Transparency Act and set expectations that offshore wind turbines, upon completion, should meet the criteria outlined in the EU Taxonomy.
1. Proactima has provided the following input for the consultation on pre-qualification criteria for the ministry’s work on allocation in Utsira Nord and the initial areas in Southern North Sea II:
Proactima believes that concession allocations should incentivize actors to promote and further develop a high level of safety and working environment within their operations. Proactima notes that pre-qualification criterion 2E concerning HSE is very concise and only allows for an assessment based on pass/fail for minimum requirements. In the subsequent allocation model, HSE is not weighted beyond meeting the minimum requirements.
Given that bottom-fixed and floating offshore wind in Norway is an immature industry, while there are ambitious plans to develop it into a comprehensive activity, it is crucial to provide incentives to promote and further develop a high level of safety and working environment within the industry.
HSE regulations for offshore wind are still being established, with varying expectations among actors regarding necessary content. The concession allocations can contribute to fostering expectations and practices that are tailored to the risk conditions, the actor landscape, and the industry’s maturity. Additionally, they should align with the industry’s competitiveness nationally and internationally.
We believe that concrete initiatives and activities should be requested from actors regarding how they will promote and further develop a high level of safety and working environment within their operations, and that this should be included in the prioritization within the allocation model. Relevant topics for assessment may include:
Actors must be capable of delivering good HSE performance, partly because this industry will not be risk-free, and partly because the foundation of risk assessment is incomplete. Furthermore, floating offshore wind in Norway is different and more complex than what has been done elsewhere in the world.
2. Proactima believes that the ministry needs to clarify how the responsibility for HSE should be addressed within a consortium.
The consultation document describes that a consortium can collectively meet the pre-qualification requirements. Proactima believes that there should be requirements to describe how the responsibility for HSE and risk management, including the management system, should be comprehensively addressed within a consortium. This will ensure that actors work proactively and systematically with these aspects and establish clear and unambiguous lines of responsibility to effectively manage HSE and risk.
3. Proactima hopes for a stronger sustainability dimension.
Proactima acknowledges that the allocation criteria emphasize the sustainability dimension, with a particular focus on the recycling and reuse criterion contributing to increased attention and operationalization of the circular economy. In addition to the expectation of compliance with environmental legislation, Proactima hopes that the ministry will specifically include requirements in the Transparency Act. This act sets requirements for the implementation and follow-up of decent working conditions and human rights in the value chain during project development. Lastly, Proactima expects the ministry to set expectations that offshore wind turbines, upon completion, should meet the criteria outlined in the EU Taxonomy, as proposed in future legislation on sustainability and sustainability reporting.
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