3 August 2020
By Email Only:
The Rt. Hon. Kwasi Kwarteng
Minister for Business, Energy and Clean Growth
Department for Business, Energy & Industrial Strategy
1 Victoria Street
OFFSHORE TRANSMISSION NETWORK REVIEW (“REVIEW”)
SASES and SEAS are two groups of East Suffolk residents which have been seeking to find a more sustainable way for offshore energy to be brought onshore and connect to the National Grid. As you are aware East Suffolk is overburdened with energy projects with eight offshore projects planned for our area together with the proposed development of Sizewell C, all of which will involve development in the Suffolk Coasts and Heaths AONB. In addition other parts of the UK, most notably Norfolk, have similar issues with the onshore impacts of offshore energy. Accordingly we were delighted to learn of the “Offshore Transmission Network Review” and we have carefully reviewed the Terms of Reference (“TOR”).
We strongly endorse the view that offshore green energy is a good thing. We also share the view that the onshore connections of offshore developments must not cause considerable irreparable damage to coastal communities and the environment, which is the present position in the absence of any overarching, holistic, approach.
We are of course confident that this Review is intended to be a serious exercise and not one designed to push the concerns of those whose communities and lives are badly affected by onshore connections into the long not so “green” grass.
In these circumstances we note that the TOR does not set out any details of the way in which the Review is to take place save to say that it will “be led by the Department for Business, Energy & Industrial Strategy (BEIS) with support from a range of government and Industry bodies and an industry expert group.” It also refers to future consultations.
You will appreciate that representatives from outside of the industry and sector will wish to be satisfied that the Review group is objective and independent and not dominated by industry representatives whose interests will be at odds with those of onshore communities.
Could you please assist in answering the following questions.
1. When the TOR was being drafted did BEIS consult with the industry? If so why did it not consult also with representatives of onshore communities?
2. Who is to lead the Review?
3. Will that person be independent of industry, and if not why not?
4. How large will the Review team be?
5. What range of specialist qualifications will the Review team have?
6. What powers will the Review team have to call for evidence or verify the accuracy and objectivity of submissions provided to them?
7. The TOR refers to the group including “Industry” bodies and an “Industry” expert group. Why does the membership not include representatives of onshore communities?
8. How will you ensure that these “industry” groups do not dominate the agenda and serve their own commercial interests?
9. Why are the TOR drafted to exclude projects where connection is to occur before 2026? This substantial exclusion seems to be explicitly designed to enable existing projects to be waved through irrespective of the damage that they might cause to local, onshore, environments and communities. Over the next few years huge damage to onshore communities could be caused by existing plans.
10. The issue being reviewed is one of real complexity - what is the time scale anticipated for a report? The TOR refers to an “update by the end of the year, with a view to providing clarity for an enduring approach in 2021”. What is meant by this?
11. If “clarity” is sought in 2021 does this assume that the entire Review will be completed relatively early in 2021? If so, how can the Review team ensure thoroughness?
12. Can you please confirm that the Secretary of State will, when taking decisions about current DCO applications, which will using the terminology in the TOR “connect to the onshore network”, take the conclusions of the Review into account in addressing any recommendations from the relevant Examining Authorities.
We look forward to hearing from you.
M: 07788 870823
cc Therese Coffey MP, George Freeman MPSuffolk County Council - Matthew Hicks, Richard Rout, Andrew ReidEast 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.