OSW0034
Written evidence submitted by
Local Government Association Coastal Special Interest Group
The Local Government Association Coastal Special Interest Group (LGA Coastal SIG) currently comprises more than 50 Local Authorities from around the coast of England and aims to champion and represent the collective interests of coastal, estuarine and maritime communities by increasing awareness and debate on environmental, economic and social issues at all levels in relation to the English coast.
Communities on our coast are most at risk of the effects of climate change and many are also impacted by the land-based infrastructure from offshore wind farms, often in areas of high environmental and landscape value. Changes must be made to ensure these communities may also benefit from the large-scale development of offshore wind, both now and long into the future. Although we support the development of marine renewable energy, this cannot be at the expense of our coast and its communities. The LGA Coastal SIG welcomes that this inquiry considers the environmental and social impacts of offshore wind installations.
1.1 The step-change in ambition, scale and extent requires a strategic approach
The scale of ambition for offshore wind development requires the rapid acceleration of offshore wind farm construction, including transmission infrastructure within and adjacent to coastal communities. The new sources of generation offshore mean that distribution of generation and connection infrastructure in the UK has a new geography. Development of this scale is often unknown in these areas, so the magnitude of change and consequent harm for communities and the natural environment is significant.
The multiple applications for offshore wind development are not being considered ‘in combination’ in a strategic way. The current project-by-project approach of identifying cabling routes is piecemeal, creating long-term, ongoing uncertainty and disturbance to people and the environment in those areas likely to receive multiple landfalls. Such an approach also misses opportunities for more efficient co-developed management and transmission of energy from offshore to onshore grid connections. As a result, coastal communities are facing more chronic intrusion and opportunities for strategic benefits are being lost.
Coastal communities and the coastal and marine environment are particularly sensitive to and affected by rising seas and climatic change; yet under the current approach, they are being disproportionality impacted by an industry seeking to reduce climate impacts.
1.2 The uneven distribution of economic and social benefits should be addressed
The adverse impacts of the onshore elements of offshore wind development are compounded by the fact that connection infrastructure is not usually co-located with operation and maintenance sites, so the project impacts are not offset by any local economic and skills benefits. The economic growth and associated benefits are, ordinarily, in port towns which boost growth and jobs. However, the cable landfall is often in rural locations where communities are significantly impacted, but largely with no compensating features in terms of jobs, growth, or a boost to their economy. This also creates a challenge for Local Authorities: we represent a broad range of communities, some of which are benefiting economically, whilst many are not.
1.3 Community Benefits: moving beyond community benefit funds
The established practices of the past, in terms of “community benefits”, are not sufficient to deal appropriately or fairly with the impacts of offshore wind development on these communities.
Most communities do not have the knowledge, confidence or resources to engage effectively, to secure community benefits and compensation, at an early stage in the process. These issues are explored in detail in the 2017 paper Understanding community benefit payments from renewable energy development.
The heterogeneity in the make-up, needs and priorities of coastal communities around England means that a one-size-fits-all approach to community benefits is not fit for purpose. We strongly advocate for early, consistent and transparent engagement with local communities and local authorities, to enable meaningful dialogue and ensure communities understand the opportunities from offshore renewables, as well as the risks and impacts.
There is much to be learned from Scotland, e.g. Scottish Government Good Practice Principles for Community Benefits from Offshore Renewables Energy Developments. Although not directly transferrable, we recommend government develops clear guidance for England with developers, local government and local communities.
The scale of opportunity is vast and we must ensure that, as this step-change in offshore wind development materialises, our coastal communities receive meaningful benefits alongside the change and disruption. This will require a move beyond community funds towards additional investment into tackling the most pressing issues to our coast and its communities.
1.4 Offshore wind and climate change adaptation – a risk and an opportunity
Offshore wind in now a maturing industry which is attracting major investment. The income streams for both the private sector and the Government, via the Crown Estate are substantial, e.g. Offshore Wind Opportunities for Trade and Investment.
Many of the coastal areas essential for the development of offshore wind face significant climate adaptation challenges, including eroding coastlines, the displacement of coastal communities, the loss of agricultural land and the ingress of seawater into the aquifers used for irrigation and public water supplies.
The Shoreline Management Plans set out our coastal management policies. Both traditional defences or more adaptive measures are expensive. These measures are essential to safeguard the land and communities that support the offshore energy industry and host its connection sites, as well the protect the infrastructure itself. All around England, local authorities are exploring innovative tools and approaches to help people and assets to relocate away from high risk areas but we currently have no funding to support our work.
Funding streams from offshore renewables could contribute to this expenditure and safeguard the ports, landfalls, coastal communities and coastal transmission infrastructure that is required to support offshore energy generation and the Net Zero ambition.
At present there are no specific national funding mechanisms to assist coastal settlements to adapt to climate change but there are now case studies, where funding has been available, illustrating how communities can successfully adapt.
1.5 A funding mechanism for strategic climate adaptation is required
We propose that a Coastal Adaptation and Resilience Fund is created to enable offshore wind developer contributions to be brought together with central government and private funds to facilitate coastal adaptation and resilience measures that support our wind energy ports, landfalls and coastal communities for the future.
This fund would be specifically for the delivery of traditional and adaptive coastal risk management measures. The fund could:
Partially redress the impacts to local communities from wind farm infrastructure,
Allow Local Authorities to augment existing coastal protection schemes or fund new initiatives.
To deliver community adaptation to sea level rise and net zero outcomes for the health and wellbeing of our communities and habitats and to boost local economies.
Contributions from offshore developments and The Crown Estate leasing revenue could then be integrated with Defra expenditure on coastal management.
This would also facilitate greater dialogue and encourage partnership working between developers, local authorities and communities through the lens of place-making. Local authorities want to support appropriate development for the benefit of our communities, the environment and the economy. Many of our members have declared their own climate emergencies and fully support the drive for a net zero UK, but our coastal communities should not continue to bear the brunt in the name of the national good without compensatory measures.
At present, with multiple major energy projects being proposed and delivered along the coast, in addition to other significant projects and the complex and ongoing task of competing local government functions, all alongside a backdrop of an uncertain financial landscape, the resourcing, planning and engagement necessary to seek suitable outcomes for communities through the current wind energy processes is extremely challenging.
1.6 Environmental impacts should be addressed strategically
There is a strategic approach to offshore ecological impacts, through the plan level HRA process and the Offshore Energy Strategic Environmental Assessment. To date, the cumulative impacts on communities and the onshore environment from the pipeline of projects needed to deliver net Zero by 2050, has not been considered in the same strategic manner. Ideally, this would then be completed in parallel to the identification of seabed bidding areas, rather than solely at the project consenting (Development Consent Order application) stage.
A mechanism for co-ordination between Local Planning Authorities, The Crown Estate, and onshore statutory consultees would be required. This would be similar to the Expert Working Group used to build the evidence base for the plan level HRA offshore. In addition, the scope of the Offshore Wind Strategic Environmental Assessment could be expanded to cover terrestrial issues, in the areas likely to host connection infrastructure for each seabed allocation area.
A strategic approach to assessing the onshore impacts of offshore wind would help to inform individual project design at an early stage as it does offshore.
1.7 The connection offer process should be reformed to be more sensitive to environmental risks and their associated costs at an early stage
The connection offer process is also not sufficiently robust in its preliminary evaluation of environmental effects and their potential impact on both project cost and consenting risk. Whilst the Connection Infrastructure Option Note (CION) process of the National Grid Electricity System Operator (NGESO) does include mention of environmental risk it does not deal with this effectively. As it operates at present the environmental information for a connection proposal is provided by the developer to NGESO without any examination of its scope or veracity by any other party. This is a consequence of the closed design of the process, intended to protect commercial sensitivities.
This is not satisfactory or robust. Although we do recognise the need for a confidential process, we believe it should be possible design a process to allow key statutory consultees/regulators, Natural England and the Environment Agency to scrutinise the quality and scope of the environmental information, to identify any issues with it or additional matters they believe should be considered NGESO and the developer.
1.8 The conflict between offshore wind development and coastal environmental designations is not adequately addressed
There needs to be greater recognition in our local and national planning decisions of the conflict between designated sites on the coast, which have been designated on behalf of the nation for wildlife and people, and the need for offshore wind infrastructure coming ashore. Many of our coastal areas are Areas of Outstanding Natural Beauty, equal in planning terms with National Parks. The consideration of the impact of coastal and offshore development on land within this designation, and (crucially) its setting should be required. This follows the approach taken when determining planning applications within the setting of National Parks.
There should also be greater consideration of the appropriate role of the ‘biodiversity net gain’ principle for wind developers; at present, Nationally Significant Infrastructure Projects and any projects in the marine environment are currently outside the scope of Biodiversity Net Gain. As set out in “Net Gain Summary of Responses and Government Response - July 2019” significant habitat improvement opportunities exist in our coastal zones, including those which provide the much-needed ecosystem services of carbon sequestration and coastal protection, e.g. saltmarsh habitats which bank carbon and support fisheries alongside sand and shingle environments which together provide natural coastal protection from coastal change.
2.1 The current regulatory framework stifles innovation to deliver Net Zero and limits options for reducing the environmental and social impact of offshore wind and connection infrastructure
The current policy and regulatory arrangements are almost entirely focussed on minimising the cost to the consumer of individual projects. This approach militates against the efficient use of both land and seabed to connect offshore wind to the National Grid network through hybrid connection schemes, meshed grids and anticipatory rather than reactive development of new connections. As a consequence, the cumulative environmental and social impacts of offshore wind projects are increased. The creation of a meshed grid in and across the southern north sea faces significant regulatory hurdles which are addressed in the report Regulatory and financing principles for a meshed HVDC offshore grid.
Ofgem has committed to working with government and industry to review the frameworks for connecting offshore wind generation, and will explore whether a more coordinated offshore transmission system could reduce both financial and environmental costs, both onshore and to benthic habitats and species.
2.2 Multiple radial connections waste the limited options for onshore connection points
The multiple radial connections are profligate in their use of the very limited number of suitable locations for cables to make landfall. The safeguarding and stability of landfall locations will be key to securing energy supplies. New landfall sites need to consider both the landward erosion of the coast alongside the potential for beach levels to fluctuate significantly. Safety factors need to demonstrate that such fluctuations will be designed into the proposal and monitored and mitigated for if the coast changes.
For example, long term predicted foreshore lowering should be taken into account to prevent cabling becoming exposed. Furthermore, methodologies for landfall can vary between projects. It is considered that open cut trenching (often considered the most cost efficient) has the most significant impact on coastal sites with regards to coastal processes. This methodology is also likely to reduce the natural resistance of the beach, cliff and beach platform substrates to erosion over the short to longer term. This weakness is also at the exact point of the cable landfall, thus increasing the erosion risk to the assets. As such, we recommend methodologies such as directional drilling to avoid disturbance to the cliff, foreshore and nearshore coastal processes.
Landfalls and associated infrastructure should be considered within the 100-year timescales of Shoreline Management Plans which identify how we should respond to coastal risks as a result of expected coastal change and sea level rise. Increased recognition of coastal risks by the wind energy developers is needed. We are currently “refreshing” Shoreline Management Plans nationally through the Environment Agency which may be an opportunity for the wind energy sector to engage with coastal local authorities over proposed landfall locations in a strategic way.
Coordinated and integrated connections are not a panacea, significant impacts on the environment and communities will remain to be mitigated and compensated.
Whilst meshed grids and hybrid interconnector offshore wind projects will contribute the creation of a more rational and less widespread connection infrastructure, they will not eliminate the need for very large onshore infrastructure in key locations. For example the Viking Link Converter station at Biker Fen or reinforcement and expansion of the onshore 400Kv transmission network. The impacts on communities and the environment in these locations will be significant.
Many of the locations best placed to serve the offshore wind industry are coastal port towns. These have seen significant economic decline in previous decades, as set out in in the Regenerating Seaside Towns Committee report published in April 2019. Wind energy is leading to these economies rising again, however, these towns are at tidal flood risk and will be at increasing flood risk in the future putting the wind energy infrastructure in these locations at risk.
Ports by their nature need to be by the sea and we would like to see greater integrated investment planning between flood and coastal risk management projects and wind energy development at the coast to create sustainable coastal towns with a flood resilient wind farm industry that can service the offshore need over the next 30-50 years.