7 September 2020
The Rt. Hon. Dr Kwasi Kwarteng
Minister for Business, Energy and Clean Growth
Department for Business, Energy & Industrial Strategy
1 Victoria Street
By Email Only: firstname.lastname@example.org
OFFSHORE TRANSMISSION NETWORK REVIEW (“REVIEW”)
Thank you for your letter of 1st September 2020 responding to our letter of 3rd August 2020.
We are pleased that you recognise that the concerns of groups such as ours need to be addressed.
Suffolk Energy Coast Delivery Board
Before turning to matters specifically relating to the Review we would just like to comment on your reference to the Suffolk Energy Coast Delivery Board. You may not be aware but this board lacks any transparency. The members of this board are not disclosed, the dates of its meetings are not disclosed, it meets in private and no documents relating to its deliberations are published, not even minutes of its meetings. Can this total absence of transparency be remedied please, both for the past and for the future.
Friston and the TOR
Having read the letter we are unclear as to the scope of the TOR. You will of course appreciate that the immediate concern of ours which needs to be addressed are the DCO applications recently made by Scottish Power for consents for the vast substation complex proposed to be constructed adjacent to the ancient village of Friston in Suffolk. The evident intention behind the applications is that, once consents are obtained, the site will also be used for a series of further substations and infrastructure, much of which is to be constructed by the National Grid group.
A number of questions posed in our earlier letter were intended to seek confirmation that our concern that the proposed substation complex at Friston had been excluded from the review was unfounded. With respect, that specific question has not been clearly answered.
In your letter you suggest that projects that are “nearing the end of the consenting process” are excluded.
Can we therefore take it that the present DCO applications for Friston, for which the examination process has yet to start, and which has been delayed by the Covid crisis, is not being treated as nearing the end of a consenting process. In other words it falls within the scope of the Review. As you are aware the TOR state that “the medium-term workstream will seek to:
• identify and implement changes to the existing regime to facilitate coordination in the short-medium term [emphasis added]
• assess the feasibility and costs/benefits of centrally delivered, enabling infrastructure to facilitate the connection of increased levels of offshore wind by 2030 [emphasis added]
• explore early opportunities for coordination [emphasis added] through pathfinder projects, considering regulatory flexibility to allow developers to test innovative approaches
• focus primarily on projects expected to connect to the onshore network after 2025 [emphasis added]
Our understanding of your letter and the TOR is that the Scottish Power projects including the proposed Friston substation complex are not excluded and are therefore included in the Review. Please confirm that our understanding is correct and provide us with a clear and unequivocal
Representation in the Review
We note that those conducting the Review and the proposed expert group advising them do not include anyone who might have an interest in opposing, or who are concerned about, the inappropriate development of large scale onshore infrastructure. As you know we are strongly in favour of offshore wind energy but are deeply concerned by the uncoordinated, inefficient and environmentally damaging onshore developments being proposed to support offshore energy. Your letter explains that National Grid ESO has played a part in developing the TOR. It has a clear interest in minimising the ability of groups, such as ours, to have an input into the Review since this might be adverse to their own private commercial interests. Indeed they will have a long term commercial
stake in the Friston substation complex.
Can you please explain (i) why groups such as ours have been excluded, (ii) whether local authorities have been included or excluded and (iii) the steps that you will take to ensure that the Review is truly independent and impartial aside from the establishment of an independent expert advisory group.
Further can you please confirm that we will be invited to the virtual webinar which is scheduled for the Autumn.
Other Offshore Electricity Projects
The Review is focused on the offshore transmission regime and its onshore impacts. Whilst the Review may have been prompted by the need to develop offshore wind generation, could you please confirm that the Review will address the onshore impacts of all offshore electricity projects including both UK and international offshore interconnector projects.
We look forward to your response. We are all keen to ensure that this Review does not become, what many already fear, an exercise in throwing potential opposition to uncoordinated, inefficient and environmentally damaging onshore energy developments into the longest of long grass. We would ask for a quick response. Please note we intend to publish all of the correspondence passing between us.
M: 07788 870823
cc Therese Coffey MP, George Freeman MP
Suffolk County Council - Matthew Hicks, Richard Rout, Andrew Reid, Russ Rainger
East Suffolk Council - Steve Gallant, Craig Rivett, James Mallinder, Jocelyn Bond
Looking at the existing regimes, questions have arisen regarding the suitability of the current regulatory regime for offshore wind. It is currently heavily concentrated on competitiveness, which is considered beneficial for consumers. That means that currently there is no sharing of infrastructure, and each wind farm has an individual connection to transmit the power that it generates. There are three material concerns with this: it is financially inefficient; it has a negative environmental impact; it may have a negative impact on coastal communities where connections make landfall.
Eight Offshore Wind Energy Projects are widely believed to be planned to connect to the National Grid at Friston (this does not include future windfarm projects as a result of the seabed leases awarded by the Crown Estate in relation to the Round 4 process). Cumulative impact means eight substations and interconnectors constructed sequentially or consecutively. Plus, the addition of a nuclear power station, one of the largest in the world. This will be the largest complex of energy infrastructure in the U.K. situated in one of the most fragile ecosystems in the U.K. These are judged to be ill-conceived plans where the process of choosing the site for the mega infrastructure hub is shown to be flawed. There are a number of better alternative brownfield sites for this designated vast complex.