Management Measures Tool for Marine Energy

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Accessing Management Measures that Support Deployment of Wave and Tidal Energy Devices

As the marine renewable energy (MRE) industry moves beyond deployment of individual wave and tidal energy devices towards arrays, certain risks of MRE devices on the marine environment are not well understood and have led to onerous monitoring requirements placed on device developers.

A workshop was held in May 2017 with researchers, regulators, and developers to create the basis for the tool shown below. In consultation with the research and regulatory communities, it was agreed that applying a set of robust management measures could act as safeguards for marine animals and habitats until available monitoring data allows for determining the level of risk from MRE devices. At that point, measures could be dialed back or removed, if warranted. More information on the workshop and input for the tool can be found here.

The Management Measures Tool for Marine Energy shows management (or mitigation) measures from past or current MRE projects as a reference to help manage potential risks from future projects and allow them to move forward in the face of uncertainty, or until a risk can be retired. Additional management measures are regularly added by the OES-Environmental team. In addition to the searchable tool below, the information can be downloaded here. The download file includes additional details not shown below, including comments from stakeholders on past experience, cost of management measures, and when a management measure is needed.

View the instructions document for more in-depth details and examples on how to use the Management Measure Tool for Marine Energy or check out this webinar for an overview and demonstration of the tool. 

Last updated January 2023

Displaying 301 - 339 of 339 management measures
Technology Project Phase Stressor Receptor Management Measure Advantages Challenges Project Documents
Tidal Operation & Maintenance Collision risk

Potential for collision with turbine blades.

Birds
Diving birds
Mitigation

Design proportion of swept area to structure area to minimise collision risk.

Could reduce the likelihood/consequence of potential collision events.

Can be a high cost associated with this.

Can present financial, logistical, or design challenges to technology developer to alter design of device.

Wave, Tidal Operation & Maintenance Entanglement

Potential for marine animals to become entangled in device mooring lines and cables.

Fish
Elasmobranch, large fish
Design feature, Monitoring

Routine inspections of mooring lines. Implement features into existing control systems to detect entanglement events.

Remove/reduce risk of entanglement.

Likely to be required as part of the technical monitoring of the device and therefore not an additional cost

Could be a costly measure for technology developers if not required as part of technical monitoring of device.

Argyll Tidal Limited 2013, European Marine Energy Centre (EMEC) 2014, Xodus Group 2019, Federal Energy Regulatory Commission (FERC) 2020, Argyll Tidal Demonstrator Project, EMEC Fall of Warness Grid-Connected Tidal Test Site, EMEC Billia Croo Grid-Connected Wave Test Site, PacWave South Test Site
Tidal Operation & Maintenance Changes in water flow

The potential wider or secondary effects (siltation changes or smothering) on protected or sensitive littoral habitat due to changes in tidal flow around devices and associated moorings, support structures, or landfall cables.

Habitat
Benthic invertebrates
Monitoring

Pre and post installation monitoring of sensitive benthic communities, based on visual surveys.

Reduce scientific uncertainty.

Interpretation of data for statistical purposes may not have power to detect change generated by impact.

May require correlation with detailed Computational Fluid Dynamics studies and physical flow measurements.

Orbital Marine Power 2014, European Marine Energy Centre (EMEC) 2011, Davison and Mallows 2005, ScottishPower Renewables 2010, The Marine Institute 2016, Orbital Marine Power 2018, EMEC Shapinsay Sound Scale Tidal Test Site, Strangford Lough - MCT (SeaGen), Sound of Islay Demonstration Tidal Array, Galway Bay Test Site, Orbital Marine Power O2 at EMEC
Wave, Tidal Installation, Operation & Maintenance, Decommissioning Marine Non-Native Species (MNNS)

Potential for introduction of MNNS which can have an adverse impact on the native species at the site.

Habitat
Mitigation

Establish and implement a Biofouling Management Plan.

Reduce/remove risk of transfer of non-native species.

Lack of industry specific guidance.

European Marine Energy Centre (EMEC) 2014, Xodus Group 2019, Orbital Marine Power 2018, EMEC Fall of Warness Grid-Connected Tidal Test Site, EMEC Billia Croo Grid-Connected Wave Test Site, Orbital Marine Power O2 at EMEC
Wave, Tidal Installation, Operation & Maintenance, Decommissioning Contamination

Potential for accidental or unplanned events which could lead to contamination of the marine environment.

Marine Mammals
Design feature

Physical Containment systems including bulk heads, closed circuit systems, pressure relief systems.

Reduces risk of contamination/pollution escaping from structure.

Foubister 2005, MeyGen 2012, Royal Haskoning and Sea Generation (Kyle Rhea) Ltd. 2013, Sustainable Energy Authority of Ireland (SEAI) 2011, The Marine Institute 2016, THETIS Energy 2009, EMEC Fall of Warness Grid-Connected Tidal Test Site, MeyGen Tidal Energy Project , Kyle Rhea Tidal Stream Array Project, Atlantic Marine Energy Test Site (AMETS), Galway Bay Test Site, Torr Head Project
Wave, Tidal Installation, Decommissioning Underwater noise

The potential effects from underwater noise generated during installation/construction (excluding piling).

Marine Mammals
Mitigation

Avoid/limit 'noisy works' within close proximity to sensitive sites (e.g., known seal haul outs during sensitive periods, defining appropriate clearance distances where necessary).

Could reduce potential effects on sensitive species during sensitive periods.

Could increase project construction timescales (e.g., if continuous drilling time is restricted or specific periods need to be avoided).

Orbital Marine Power 2014, Xodus AURORA 2010, Aquatera Ltd 2011, European Marine Energy Centre (EMEC) 2014, Davison and Mallows 2005, Xodus Group 2019, ScottishPower Renewables 2012, McGrath 2013, Aquatera 2017, The Marine Institute 2016, Federal Energy Regulatory Commission (FERC) 2020, DP Energy Ltd. 2017, HS1000 at EMEC, Wello Penguin at EMEC, EMEC Fall of Warness Grid-Connected Tidal Test Site, Strangford Lough - MCT (SeaGen), EMEC Billia Croo Grid-Connected Wave Test Site, Fair Head Tidal Array, Tocardo InToTidal at EMEC, Galway Bay Test Site, PacWave South Test Site, Fair Head Tidal Array
Wave, Tidal Operation & Maintenance Entanglement

Potential for marine animals to become entangled in lost fishing gear or other equipment trapped on infrastructure.

Reptiles
Sea turtles
Monitoring

Ensure standard notifications of loss of fishing gear in region notified to operators. Reporting of entanglement events.

Good practice for emergency preparedness.

Chances of lost fishing gear being reported is reportedly low.

Wave, Tidal Installation, Operation & Maintenance, Decommissioning Contamination

Potential for oil spill incident resulting from the influence of unfavourable weather conditions.

Benthic
Mitigation

Vessel activities to occur in suitable weather conditions.

Reduces the chance of oil spill to the environment.

MeyGen 2012, Aquamarine Power Ltd 2011, ScottishPower Renewables 2012, MeyGen Tidal Energy Project , Oyster 800 at EMEC, Pelamis Wave Power P2 Demonstration at EMEC
Wave, Tidal Installation, Operation & Maintenance, Decommissioning Marine Non-Native Species (MNNS)

Potential for introduction of MNNS which can have an adverse impact on the native species at the site.

Benthic
Compliance

Compliance with all relevant guidance (including IMO guidelines) regarding ballast water management and transfer of non-native species.

Reduce/remove risk of transfer and settlement of non-native species.

MeyGen 2012, McPherson 2015, OpenHydro and SSE Renewables 2013, European Marine Energy Centre (EMEC) 2014, Xodus Group 2019, Magallanes Renovables 2020, Royal Haskoning and Sea Generation (Kyle Rhea) Ltd. 2013, SSE Renewables 2011, Tidal Lagoon Power 2017, Federal Energy Regulatory Commission (FERC) 2020, MeyGen Tidal Energy Project , Nova Innovation - Shetland Tidal Array, Brims Tidal Array, EMEC Fall of Warness Grid-Connected Tidal Test Site, EMEC Billia Croo Grid-Connected Wave Test Site, Magallanes Renovables ATIR at EMEC, Kyle Rhea Tidal Stream Array Project, Westray South Tidal Project, Swansea Bay Tidal Lagoon (SBTL), PacWave South Test Site
Wave, Tidal Operation & Maintenance Contamination

Potential for oil/hydraulic spill incident resulting from the maintenance activities.

Fish
Mitigation

All maintenance activities involving oil/hydraulic fluid treatments will be carried out on-shore.

Reduces the chance for oil spill to the environment.

Foubister 2005, EMEC Fall of Warness Grid-Connected Tidal Test Site
Wave, Tidal Installation Barrier to movement

Potential barrier to movement due to the physical presence of devices and associated moorings/support structures, cables and electrical equipment.

Fish
Design feature

Array/mooring configuration designed to avoid migratory routes or other important sites

Minimizes risk of development acting as a barrier to movement by avoiding migratory routes or other important sites.

May be inconsistent with optimal layout of the development for exploitation of the energy source.

Can be a costly measure when scaling up to larger arrays.

Aquamarine Power Ltd 2011, Davison and Mallows 2005, Oyster 800 at EMEC, Strangford Lough - MCT (SeaGen)
Wave, Tidal Operation & Maintenance EMF

Impacts of electromagnetic fields from subsea cables on sensitive species.

Fish
Migratory fish, elasmobranchs
Design feature

Install cable protection, armor, rock placement, or other cable protection.

Reduce the level of EMF to surrounding water column and therefore any potential effects.

Reduces 'snagging risk' for vessels.

Creation of artificial habitat.

May have an impact on surrounding benthic habitats and sensitive species

Creation of artificial habitat may cause aggregation effect causing greater impact of EMF.

Increased cost to project.

Reduced possibilities for decommissioning in future.

Orbital Marine Power 2014, Foubister 2005, McGrath 2013, Federal Energy Regulatory Commission (FERC) 2020, EMEC Fall of Warness Grid-Connected Tidal Test Site, Fair Head Tidal Array, PacWave South Test Site
Wave, Tidal Operation & Maintenance Lighting

Potential for lighting to adversely affect nocturnal and migratory species.

Fish
Design feature

Consider type, colour and use of lighting during design and consultation with navigational stakeholders.

Could redcue impacts on sensitive species if they are known to use or migrate near to the project site.

Navigational saftey need to be considered at all times and may take precedent over ecological needs.

DP Energy Ltd. 2013, European Marine Energy Centre (EMEC) 2014, Tidal Lagoon Power 2017, West Islay Tidal Project Energy Park, EMEC Fall of Warness Grid-Connected Tidal Test Site, Swansea Bay Tidal Lagoon (SBTL)
Wave, Tidal Operation & Maintenance Contamination

Potential for oil/hydraulic spill incident resulting from the maintenance activities.

Habitat
Mitigation

All maintenance activities involving oil/hydraulic fluid treatments will be carried out on-shore.

Reduces the chance for oil spill to the environment.

Foubister 2005, EMEC Fall of Warness Grid-Connected Tidal Test Site
Tidal Operation & Maintenance Changes in water flow

Modifications to prey distribution and abundance (to include for other receptors) resulting in changes to foraging behaviour.

Marine Mammals
Monitoring

Observational surveys (including remote sensing) of bird and marine mammals (prey availability linked to benthic community).

Reduces scientific uncertainty.

Statistical power of studies can be low. Can be difficult to distinguish between natural variation and direct effects of energy removal from the system.

Monitoring may be expensive.

Aquamarine Power Ltd 2011, GlaxoSmithKlineMontrose 2012, Orbital Marine Power 2014, Tidal Energy Ltd 2008, Xodus AURORA 2010, European Marine Energy Centre (EMEC) 2011, Davison and Mallows 2005, McGrath 2013, Xodus Group 2012, Orbital Marine Power 2018, Oyster 800 at EMEC, GSK Montrose Tidal Array, Ramsey Sound, HS1000 at EMEC, EMEC Shapinsay Sound Scale Tidal Test Site, Strangford Lough - MCT (SeaGen), Fair Head Tidal Array, Orbital Marine Power O2 at EMEC
Wave, Tidal Installation, Operation & Maintenance, Decommissioning Displacement

Potential displacement of essential activities due to the presence of devices and associated moorings/support structures.

Marine Mammals
Design feature

Array/mooring configuration designed to avoid migratory routes or other important sites.

Minimizes risk of development creating displacement by avoiding migratory routes or other important sites.

May be inconsistent with optimal layout of the development for exploitation of the energy source.

Can be a costly measure when scaling up to larger arrays.

Aquamarine Power Ltd 2011, Davison and Mallows 2005, Oyster 800 at EMEC, Strangford Lough - MCT (SeaGen)
Wave, Tidal Decommissioning Vessel disturbance

Potential for disturbance from project vessels.

Marine Mammals
Cetaceans, seals
Mitigation

Limit use of vessels, e.g. one vessel present with regular use of thrusters to maintain position.

Reduces potential disturbance effects.

Low 2012, MeyGen 2012, Atlantis Resources Corporation at EMEC, MeyGen Tidal Energy Project
Wave, Tidal Installation, Operation & Maintenance, Decommissioning Marine Non-Native Species (MNNS)

Potential for introduction of MNNS which can have an adverse impact on the native species at the site.

Reptiles
Monitoring

Monitoring and reporting of MNNS.

Reduces/removes risk of transfer of non-native species.

Wave, Tidal Operation & Maintenance EMF

Impacts of electromagnetic fields from subsea cables on sensitive species.

Benthic
Benthic invertebrates
Design feature

Bundle cables together to reduce field vectors.

Reduce the level of EMF to surrounding water column and therefore any potential effects

Less redundancy in system.

Potential commercial and technical feasibility issues.

MeyGen 2012, MeyGen Tidal Energy Project
Wave, Tidal Installation, Decommissioning Changes in sediment dynamics

Sediment disturbance disrupting water clarity that results in smothering of fish spawning grounds.

Birds
Mitigation

Best practice methodologies to reduce resuspension of sediment during cable burial or device foundation/mooring installation.

Sustainable Energy Authority of Ireland (SEAI) 2011, The Marine Institute 2016, Federal Energy Regulatory Commission (FERC) 2020, Atlantic Marine Energy Test Site (AMETS), Galway Bay Test Site, PacWave South Test Site
Wave, Tidal Operation & Maintenance Entanglement

Potential for marine animals to become entangled in device mooring lines and cables.

Birds
Diving birds
Design feature

Minimise the number of mooring lines.

Reduce risk of entanglement.

Could be a costly measure for technology developers.

Tidal Operation & Maintenance Changes in water flow

The potential wider or secondary effects on protected or sensitive sub-littoral seabed due to removal or alteration of energy flow arising from devices and moorings or support structures.

Fish
Monitoring

Modelling to predict the interaction between changes in tidal flow, flux, and turbulence structure and animals.

Reduces scientific uncertainty so appropriate management measures can be employed.

Limited management measures available to minimise interaction despite modelling to fully predict interaction.

Wave, Tidal Operation & Maintenance EMF

Impacts of electromagnetic fields from subsea cables on sensitive species.

Fish
Elasmobranchs
Design feature

Bundle cables together to reduce field vectors.

Reduce the level of EMF to surrounding water column and therefore any potential effects.

Less redundancy in system.

Potential commercial and technical feasibility issues.

Greater costs associated with not laying direct cable paths.

MeyGen 2012, MeyGen Tidal Energy Project
Wave, Tidal Installation, Operation & Maintenance, Decommissioning Vessel disturbance

Potential for disturbance from project vessels.

Fish
Elasmobranch, large fish
Mitigation

Reduce speed and maintain steady course when animal is sighted.

Reduces potential effects and is a relatively low cost measure.

Aquatera Ltd 2011, Magallanes Renovables 2020, European Marine Energy Centre (EMEC) 2020, SSE Renewables 2011, Magallanes Renovables 2020, Royal Haskoning 2012, Aquatera 2017, Federal Energy Regulatory Commission (FERC) 2020, Wello Penguin at EMEC, Magallanes Renovables ATIR at EMEC, EMEC Scapa Flow Scale Wave Test Site, Westray South Tidal Project, Oyster 800 at EMEC, Tocardo InToTidal at EMEC, PacWave South Test Site
Wave, Tidal Operation & Maintenance Habitat Creation

The introduction of infrastructure and artificial substrates will provide potential roosting habitat.

Habitat
Roosting birds
Monitoring

Monitor use of device as a roosting platform.

Reduces scientific uncertainty around collision risk, displacement, and other impacts.

Monitoring is relatively inexpensive to carry out.

Data mortgage (data gathered more quickly than it can be analyzed).

Tidal Operation & Maintenance Collision risk

Potential for collision with turbine blades.

Marine Mammals
Mitigation, Design feature

Install a 'detect and deter' system using a combination of active sonar and acoustic deterrent device (ADD).

Could reduce likelihood of collision with moving blades and enable a route through the consenting process.

Would rely on well proven and reliable system - efficacy of ADDs is unknown in these environments and unknown if deterrent systems will help reduce risk.

Expensive to implement.

Questions around the effects of ADDs (e.g., added noise) on sensitive species.

...Read more

Would rely on well proven and reliable system - efficacy of ADDs is unknown in these environments and unknown if deterrent systems will help reduce risk.

Expensive to implement.

Questions around the effects of ADDs (e.g., added noise) on sensitive species.

Detection systems are currently insufficient to detect animals (in particular at array scale).

Further research around ADDs which deter specific groups or species, is underway. This could be useful in deterring specific sensitive species or species groups, at a particular site. For example, University of St Andrews is seveloping an ADD which deter seals, but which don't effect cetaceans.

Read less
Harrison et al. 2015, Orbital Marine Power 2010, Keenan et al. 2011, Aquamarine Power Ltd 2011, THETIS Energy 2009, Churchill Barriers - Wave Overtopping and Tidal Flow Energy Capture, Pelamis Wave Power P2 Demonstration at EMEC, Strangford Lough - MCT (SeaGen), Oyster 800 at EMEC, Torr Head Project
Wave, Tidal Operation & Maintenance Entrapment

Potential risk of entrapment within device chambers and mooring arrays.

Marine Mammals
Mitigation

Release entrapped animal.

Animal may be deceased before they are able to be released.

Tidal Lagoon Power 2017, Swansea Bay Tidal Lagoon (SBTL)
Tidal Operation & Maintenance Changes in water flow

The potential wider or secondary effects on protected or sensitive sub-littoral seabed due to removal or alteration of energy flow arising from devices and moorings or support structures.

Reptiles
Design feature

Site selection.

Minimizes significance of interaction.

ScottishPower Renewables 2012, Ness of Duncansby Tidal Array
Wave, Tidal Operation & Maintenance Changes in sediment dynamics

The potential wider or secondary effects (siltation changes or smothering) on protected or sensitive sub-littoral seabed due to scour or siltation around devices and associated moorings, support structures and export cables.

Benthic
Monitoring

Modelling to predict the interaction between changes in sediment dynamics and animals.

Reduces scientific uncertainty so appropriate management measures can be employed.

Limited management measures available to minimise interaction despite modelling to fully predict interaction.

Foubister 2005, MeyGen 2012, Project Management Support Services 2006, GlaxoSmithKlineMontrose 2012, Orbital Marine Power SR250 at EMEC, MeyGen Tidal Energy Project , Anglesey Skerries Tidal Stream Array, GSK Montrose Tidal Array
Wave, Tidal Operation & Maintenance Habitat Creation

The introduction of infrastructure and artificial substrates will provide habitat and artificial refuges.

Benthic
Monitoring

Monitor near-field behaviours.

Reduces scientific uncertainty around collision risk, displacement, and other impacts.

Increased value/ fecundity of commercially important species.

Informs understanding of potential positivie impacts from colonization and use of project infrastructure.

This type of monitoring can be expensive and difficult to deliver in practice.

May require additional licensing (e.g. echosounders).

Foubister 2005, Magallanes Renovables 2020, Orbital Marine Power 2018, EMEC Fall of Warness Grid-Connected Tidal Test Site, Magallanes Renovables ATIR at EMEC, Orbital Marine Power O2 at EMEC
Tidal Operation & Maintenance Collision risk

Potential for collision with turbine blades.

Birds
Diving birds
Mitigation

Selective structural and blade coatings (e.g., colors to aide detection.

Unknown - it is possible that this will aid detection of subsea structures and help reduce risk.

Uncertainty around how animals use visual cues, could. Could result in 'attraction', increasing risk of collision.

Use of such measures may be limited to conform with IALA standards.

Xodus Group 2019, EMEC Billia Croo Grid-Connected Wave Test Site
Wave, Tidal Installation Marine Non-Native Species (MNNS)

Potential for introduction of MNNS which can have an adverse impact on the native species at the site.

Birds
Design feature

Avoid the introduction of hard bottom substrate into a soft bottom habitat.

Ensures the efficient recovery of species native to the surrounding habitat.

May have technical implications.

Wave, Tidal Operation & Maintenance Collision risk

Pontential risk of collision with device giving size and character of structure.

Fish
Design feature

Device components (e.g., transformer and power conditioning equipment) are designed internally.

Reduces potential for collision with external moving parts.

The Marine Institute 2016, Galway Bay Test Site
Wave, Tidal Operation & Maintenance Entanglement

Potential for marine animals to become entangled in lost fishing gear or other equipment trapped on infrastructure.

Fish
Elasmobranch, large fish
Mitigation

Fisheries management: Agreement with fishermen not to fish near to the device, warning of the dangers of losing equipment.

Reduces potential for entanglement of fishing gear in mooring lines and thus potential for entanglement of marine animals.

Xodus Group 2019, EMEC Billia Croo Grid-Connected Wave Test Site
Tidal Operation & Maintenance Changes in water flow

The potential wider or secondary effects on protected or sensitive sub-littoral seabed due to removal or alteration of energy flow arising from devices and moorings or support structures.

Habitat
Monitoring

Installation of ADCPs and turbulence sensors to better understand the baseline tidal flow conditions and hence the change in tidal flow due to presence of the device(s).

Reduce scientific uncertainty.

Tidal Energy Ltd 2008, Aquatera 2017, Ramsey Sound, Tocardo InToTidal at EMEC
Wave, Tidal Installation, Operation & Maintenance, Decommissioning Marine Non-Native Species (MNNS)

Potential for introduction of MNNS which can have an adverse impact on the native species at the site.

Habitat
Mitigation, Compliance

Adhere to appropriate measures when jettisoning ballast water.

Reduce/remove risk of transfer of non-native species.

Sustainable Energy Authority of Ireland (SEAI) 2011, Atlantic Marine Energy Test Site (AMETS)
Wave, Tidal Installation, Operation & Maintenance, Decommissioning Contamination

Potential for accidental or unplanned events which could lead to contamination of the marine environment.

Marine Mammals
Mitigation

Material selection - lubricants, coolants, hydraulic fluids etc. - selected with low ecotoxicity levels and biodegradable.

Reduces/removes risk of contamination/pollution from materials which may have escaped structure.

Use of lower toxicity materials may compromise performance, or impact other technical issues (e.g., fluid changes.)

Foubister 2005, MeyGen 2012, Xodus AURORA 2010, The Marine Institute 2016, THETIS Energy 2009, EMEC Fall of Warness Grid-Connected Tidal Test Site, MeyGen Tidal Energy Project , Galway Bay Test Site, Torr Head Project
Wave, Tidal Operation & Maintenance Underwater noise

The potential effects from underwater noise generated by wave and tidal energy converters.

Marine Mammals
Monitoring

Measure noise generated by device(s) during operation to better understand the potential effects on sensitive species.

Measured noise levels can be correlated with threshold values of relevant species and baseline noise levels of the site to determine impact and need for adaptive management measures.

Can be complex and costly to undertake this type of monitoring in high energy environments.

Data and analysis have requirement for acoustic experts.

SAE Renewables 2011, Aquamarine Power Ltd 2011, Orbital Marine Power 2014, Minesto 2016, Xodus AURORA 2010, European Marine Energy Centre (EMEC) 2019, ScottishPower Renewables 2010, Davison and Mallows 2005, McGrath 2013, Royal Haskoning 2012, Orbital Marine Power 2018, Atlantis Resources Corporation at EMEC, Oyster 800 at EMEC, Minesto Holyhead Deep - Non-grid connected DG500, HS1000 at EMEC, EMEC Billia Croo Grid-Connected Wave Test Site, Sound of Islay Demonstration Tidal Array, Strangford Lough - MCT (SeaGen), Fair Head Tidal Array, Oyster 800 at EMEC, Orbital Marine Power O2 at EMEC
Wave, Tidal Operation & Maintenance Entanglement

Potential for marine animals to become entangled in device mooring lines and cables.

Reptiles
Sea turtles
Design feature, Monitoring

Routine inspections of mooring lines. Implement features into existing control systems to detect entanglement events.

Remove/reduce risk of entanglement.

Likely to be required as part of the technical monitoring of the device and therefore not an additional cost.

Could be a costly measure for technology developers if not required as part of technical monitoring of device.