Written evidence submitted by SUFFOLK ENERGY ACTION SOLUTIONS
This submission focuses on two questions raised by the EAC:
Our campaign is called SEAS (Suffolk Energy Action Solutions) because our goal is to help the UK Government make the most of the opportunity to establish this country as the world leader in offshore wind power transmission infrastructure in terms of environmental protection and cost efficiencies.
We believe that this is the time for a step change in thinking and the time to devise a well-conceived national strategy for offshore wind power transmission infrastructure.
It is not as complicated as some suggest.
We have created a volunteer team with different skills - zoologists, wind energy engineers, entrepreneurs, farmers, environmentalists, alternative energy pioneers and tourism leaders. We are totally supportive of the shift towards energy renewables and we believe that the UK government should be focusing more on developing an umbrella strategy for offshore transmission infrastructure around the coast of East Anglia in order to optimise the principal environmental, social and economic outcomes.
We have been working with specialists across Norfolk and Suffolk, and even though our detailed submission concentrates on coastal Suffolk because that is where we live, we have joined together with Norfolk residents and councillors to explore the opportunity for the East Anglia region to be considered as one single area for the optimisation of offshore transmission infrastructure. If we were to be invited to make a presentation to the EAC, we would of course bring a team of both Norfolk and Suffolk specialists to show the plans that we have drawn up indicating an offshore modular grid around the coast of East Anglia.
The UK government has expressed its goal to become world class in its generation of energy renewables. This aim cannot be achieved if the DELIVERY SYSTEM undermines those principal outcomes.
Green energy is no longer green if the delivery system destroys unspoilt, fragile countryside, desecrates medieval villages and ravages rare habitats.
A better alternative is available. We can express this as follows:
Introductory Scope 2
Executive Summary 2
The Campaign 6
The 12 Energy Projects 7
The Cumulative Effect 8
The Immediate Threat:
SPR Windfarms 9
The Places Affected 11
The Issues 12
The Opportunity for a New
SEAS (Suffolk Energy Action Solutions) was founded in August 2019 as a grassroots campaign to make people aware of the impending onslaught of Energy projects that will descend upon East Anglia in the next 10 to 20 years.
SEAS is in favour of offshore wind energy farms.
SEAS is against the current proposed plans for the onshore delivery of that wind power.
SEAS’s mission is to make the UK Government aware of the uncoordinated plans for up to 12 Energy Projects proposed, in particular, for one small area of East Suffolk, with the inevitable economic and environmental harm they will do, causing untold hardship for its inhabitants, environment and economy.
SEAS believe that the UK Government needs urgently:
to call for an immediate moratorium to review all Offshore Wind Farm Development Consent Orders (DCOs),
to call for a cross-departmental inquiry into the adverse impacts of onshore substations, and
to create a national strategy for offshore transmission infrastructure, which incorporates offshore solutions, such as an Offshore RingMain (ORM), modular grid with substation offshore platforms and Island Hubs.
THE 12 ENERGY PROJECTS
HERITAGE COAST v ENERGY COAST
East Coast Suffolk has traditionally been called the “Heritage Coast”. Now, it is being renamed the “Energy Coast” through the emergence of 12 energy projects. This is their status:
THE CUMULATIVE EFFECT
Offshore wind projects cannot (as currently) be assessed in isolation. There is a cumulative impact from the numerous, consecutively occurring, energy projects on and around the Suffolk coast. Any proposals need to take into account the known 12 Energy Projects. Whilst all projects are considered in isolation by the planning inspectorate, local communities and environments are left vulnerable to the cumulative effects.
The Crown Estates Round 4 leasing of more North Sea bed will cause a further tsunami of windfarms and associated onshore development. Where will they land?
THE IMMEDIATE THREAT: SPR WINDFARMS
EAST ANGLIA ONE NORTH and EAST ANGLIA TWO
ScottishPower Renewables (an indirect subsidiary of Spanish multinational electric utility company, Iberdrola, SA) has submitted two applications to the Planning Inspectorate for two separate development consent orders (DCO) for the construction and operation of the East Anglia ONE North (EA1N) and East Anglia TWO (EA2) Offshore Windfarms. These were submitted to the Planning Inspectorate in tandem. Development consent for EA1N and EA2 is required to the extent that the development is or forms part of a Nationally Significant Infrastructure Project (NSIP). As NSIPs, the projects fall within the remit of the Secretary of State. If these two projects are approved, they open the flood gates for a raft of other energy projects, industrialising and concreting over currently unspoilt countryside in Coastal Suffolk.
It is unprecedented to have two DCOs assessed in tandem and to date this has caused immense confusion not just for the community but for the Planning Inspectorate, which has to duplicate all its inspection processes.
The proposed location for the offshore windfarms is in the southern North Sea, approximately 36 km and 32.6 km respectively from the Suffolk coast at its nearest point and would occupy an area of up to 208 /218 km². The landfall connection for both works will be located through the fragile cliffs north of Thorpeness, and the onshore substation and overhead line realignment works will be located in the vicinity of Grove Wood, Friston.
The Development Consent Order would, amongst other things, authorise:
THE PLACES AFFECTED
Ten communities will be hemmed in by the construction of haul roads, cable routes, substations, connectors and interconnectors for up to 15 years and probably more, as shown in the map below.
Other villages and towns from Ipswich to Lowestoft will be adversely affected by the heavy traffic and congestion caused by the increased load of HGVs and other commercial vehicles required to bring about the proposed onshore infrastructure projects. These include the popular seaside destinations of Southwold and Walberswick and the local market towns of Woodbridge and Wickham Market.
There are a number of issues that need to be considered fully within the remit of a formal review. These are the salient issues with amplifying comments:
It is unclear why a coastal area rich in wildlife and exceedingly rare habitats was chosen over brownfield sites more suited to industrialisation. Alternatives, such as ORM or Island Hubs also appear to have been overlooked in the Application.
National Grid has not answered many of the community’s questions and appear to have been absent during the consultation and the application process
Ofgem, as a consumer cost regulator, has failed since the area chosen will cost more in cabling and mitigation each time new infrastructure is built, than alternative offshore solutions and/or a brownfield site would cost - costs which will be passed on to electricity consumers.
Unsuitability of Landfall site due to fragility of Thorpeness Coralline Cliffs, shifting tidal shoreline, coastal erosion, and climate change.
The Landfall site will affect the England Coast Path and the first National Trail in Suffolk which are anticipated to bring health and economic benefits
11 km of cable trenches 50m wide destroying environmentally sensitive areas of AONB, SSSI, SPA, including The Sandlings and Fens heaths:
UK has 20% of the planet’s lowland heathland which is internationally recognised as a ‘rare habitat’. It should be actively protected and not destroyed.
Threat to wildlife: it is not possible to mitigate damage to habitats of protected or endangered wildlife such as bats, badgers, barn owls, nightingales, red deer and many species of migrating birds that live along the line of the intended cable route. For non-volant species, the destruction and modification of wildlife habitats, eg ground disturbance, is highest (Lovich & Ennen, 2013): soil compaction from heavy machinery can collapse burrows and crush small wildlife. There is no empirical research into how to mitigate any of these impacts on wildlife during construction.
Cabling: this will sever the Suffolk Coast and Heaths AONB and therefore the wildlife corridor, in turn undermining the safe haven for migrating species.
Loss of 83 acres of Grade 2 and 3 agricultural land at a time where the UK should be more self-sufficient.
Loss of woodland and hedgerows with inadequate mitigation. If not replanted with mature trees/hedgerows it can take a further 10 years (on top of the construction years) for them to mature and hide 18metre high infrastructures.
The Woodland Trust are concerned about Grove Wood, which is designated as ‘ancient’ on Natural England Ancient Woodland Inventory.
The local road network is unsuitable for the high traffic levels of construction HGVs, associated service vehicles and workforce vehicles. The increased traffic on roads will endanger cyclists, walkers and residents.
There will be inevitable delays of Emergency Services and should there be a Nuclear incident the evacuation routes would be severely hampered, both endangering lives.
Impact on tourism, The DMO survey says traffic congestion and related issues would deter tourists from coming to the area.
The Application fails to address the impact on the amenity value of the 26 PRoWs that will be permanently or temporarily closed.
There is a lack of detail on PRoW closures leading to disruption of the network, thereby leaving local walkers with very limited or no access at all.
The Landfall site will affect the England Coast Path and the first National Trail in Suffolk which is anticipated to bring economic benefits to the region
SPR’s media continually promote the job opportunities, this might be the case in Lowestoft with offshore jobs, but there are no benefits to the local community. There will be no additional local jobs, and the loss of tourism will impact Aldeburgh, Thorpeness, Snape Maltings and the surrounding villages.
The recent DMO survey states that the energy projects “could impact the local visitor economy by up to £40m per year” and has not been addressed in SPR’s application.
Typically, small businesses operate on tight margins and these businesses may not survive.
These figures are an estimation of ScottishPower Renewables EA1N and EA2’s impact on the land use of the area. They are derived from SPR document: EA2 Land Use Cumulative Impact Assessment with the Proposed East Anglia ONE North Project - Source: Preliminary Environmental Information for East Anglia TWO Offshore Windfarm, Appendix 21.1 Volume 3 Document Reference – EA2-DEVWF-ENV-REP-IBR-000816_001
Cable Route CCS's
Substation Complex at Friston
CCS x 3
Permanent footprint for 2 SS
NG Substation CCS
NG Permanent footprint*
*Unclear whether this is included in NG Substations CCS
From these proposals, we can deduce that 118 Ha of agricultural, woodland and recreational land will be appropriated during construction and at least 20 Ha removed permanently.
This would be for one project only. For six wind farm transmission infrastructure projects, these numbers would increase proportionately.
Light pollution from substations, compounds and construction areas with 24hr security lights will result in the disappearance of Suffolk’s unpolluted dark skies.
Noise pollution from traffic, construction and the substations’ constant noise during its operational life span will destroy coastal Suffolk’s valued peace and tranquillity.
Air pollution from traffic and trenches excavated through Suffolk’s light sandy soil will lead to loss of visibility and cause respiratory health issues.
THE OPPORTUNITY FOR A NEW SOLUTION
The UK is a world leader in offshore wind power. However, this will be undermined by the absence of a national strategy for transmission infrastructure.
The Crown Estate and Crown Estate Scotland maps projecting the offshore wind leasing potential of the UK’s sea beds are a matter for concern. Within 50 years the UK could be surrounded by hundreds of windfarms. The present offshore ‘point to point’ transmission system would carve up precious land at an alarming rate destroying the land required for people to live, work and play in. New innovative solutions have to be found without delay.
A recent industry report from SSE stated that the present ‘point to point’ offshore transmission grid connection system is not sustainable and offshore solutions should be put in place. This is not a new idea. Reports stating this were published for review by Ofgem, National Grid and Government in 2008, 2011 and 2015. National Grid’s input to the 2008 report titled: “UK Offshore Energy Strategic Environmental Assessment” was prophetic: Para 193. “Indeed, if coordinated development does not occur and projects are considered on a piecemeal basis, the overall network design and substation extension requirements are certain to lead to a sub-optimal solution with significant increase in the impact on the onshore network.”
The UK should collaborate closely with other North Sea countries on the development of a meshed North Sea grid, which would seek out common goals to develop more renewable energy achieved more efficiently. The European Commission report on hybrid offshore wind projects found the potential of a 10% saving.
The North Sea Wind Power Hub (NSWPH) has made massive technological advances within the last two years and has invited the UK and Norway to join them in the development of offshore energy islands.
Here is an opportunity for the UK Government, National Grid, Ofgem and Developers to work together to trial an offshore transmission energy island. Legislation appears to be the bottle neck. This should not be so, during WWI and WWII legislation was swiftly put into place to help the nation fight the war. Today, new legislation has been passed to counteract COVID-19 and enable Nightingale hospitals to be set up in a matter of weeks. It is therefore within the power of this majority Government to bring in new legislation expeditiously.
We propose, as a matter of urgency, that the necessary legislation is put in place to allow the pooling of wind power from diverse developers into a main arterial corridor (a modular grid or ORM) bringing the power to a single Mega Hub closer to the Thames Estuary with a landfall on an already industrialised site, a brownfield site, thereby negating the need for incremental onshore substations around the East Anglian coast. According to our research of other North Sea countries and their plans, the construction of offshore modular grids with offshore substation platforms can take as little as four years to implement. Currently, the principal excuses for not going ahead with these more innovative solutions are the lengthy process (“it will take ten years”) and cost. We challenge both assertions as being incorrect. The collective corridor approach proposed by SEAS is faster than a prolonged judicial review and cheaper than the currently proposed outdated approach of onshore incremental substations. The cost efficiencies gained by the pooling of wind power and by the convergence into one single Mega Hub are quantifiable.
We propose the formation of a new task force or committee, with representatives from the various relevant institutions: the National Grid, Ofgem, wind power engineers, academics specialising in step change technology, DEFRA, BEIS, developers with a focused brief, to set out the trajectory to establish an offshore solution transmission infrastructure within five years, and with a business model requiring a levy to be placed on each participating developer together with a small premium for paying customers.
This is a win-win-win concept. The environment benefits, the economy benefits and the wind power industry benefits from a more efficient and sustainable collective approach. The evolving optimisation of our renewable energy delivery system requires a national strategy, not the current adhocracy.
For more information please contact:
Fiona Gilmore: 07788 870823
Related Suffolk campaign groups:
Related Norfolk campaign group:
Facebook: Necton Substations Action Group
Yes, to Offshore Wind Energy,
Let’s Do It Right