Representation by Patricia King (Patricia King)
- Date submitted
- 30 October 2023
- Submitted by
- Members of the public/businesses
To consider alternatives in a sufficiently robust way as is warranted on a proposed £3-4 billion investment, my comment is the Examination Authority could and should invite expert written and oral testimony and welcome representations on alternatives suitable to meet the need for low-emission generation. The consideration of alternatives in the Rampion 2 Examination is a policy requirement under National Policy Statements because the Rampion 2 scheme encroaches on designated landscapes including the South Downs National Park. This consideration needs to focus on alternatives capable of delivering the same benefits as Rampion 2 (or greater benefits) including energy security, emission reductions, job creation, etc., and in the same timescale or sooner than Rampion 2. Rampion 2 output would not be available before 2030, according to the Application and considering the status of disrupted supply chains and markets for large wind turbines and risks today. As set out in relevant National Policy Statements: - NPS (2011, EN-1, para 5.9.10, under the heading - developments proposed within nationally designated landscapes - “… the development should be demonstrated to be in the public interest and consideration of such applications should include assessment of: (including) - the cost of, and scope for, developing elsewhere outside the designated area or meeting the need for it in some other way, taking account of the policy on alternatives set out in Section 4.4. “ and, - NPS 2011) EN-1 Section 3.5.6 provides the priority for considering alternatives to Rampion 2 as follows: “New nuclear power therefore forms one of the three key elements of the Government’s strategy for moving towards a decarbonised, diverse electricity sector by 2050: (i) renewables; (ii) fossil fuels with carbon capture and storage (CCS); and (iii) new nuclear”. More specifically, among the alternatives that are key elements of UK strategy which meet criteria in Section 4.4 of EN-1 are these three: (1) Considering an alternative location for Rampion turbines in strong wind regimes that fully respect strategic environment advice to avoid local harm, such as: where it is possible to add to an existing offshore wind licence award (where in this case the opportunity arises with the same developer RWE) – assuming political will for negotiated outcomes and innovation overwhelmingly in the public interest; (2) Considering retrofitting existing combined-cycle gas turbine power stations with carbon capture and storage (CCS), this given that natural gas power stations close to load centres form the bulk of UK generation assets in the south, and in light of the UK Government ambition to have carbon storage facilities in operation by 2030; and (3) Considering the deployment of small modular nuclear reactors (SMRs) at a fraction of the cost and time as large nuclear to be co-located initially with decommissioned nuclear power station sites (9 sites expected to be decommissioned by 2030), as well as co-locating new large nuclear, where all power interconnections are already available and planning approval is less problematic. Among government and industry actors and academia the Examination Authority may wish to encourage or directly invite to offer relevant expert testimony include representatives of: ? The Net-Zero Teesside (NZT) with a DCO application now advancing a 850 MW gas-fired power station with carbon capture, utilisation and storage (CCUS) to be operational in 2026 if consented in November 2023; https://infrastructure.planninginspectorate.gov.uk/projects/north-east/the-net-zero-teesside-project/?ipcsection=relreps&relrep=44475 ? Other actors in government and the power industry on the retrofit or new gas-fired power plant on the south coast (i.e., power stations fitted with post-combustion Co2 capture of the exhaust gas, which is then shipping for on-use in industry, or sent to carbon storage facilities established under the UK Government’s Carbon Capture, Usage and Storage (CCUS) cluster sequencing process by barge). The UK expects to achieve between 20 and 30 million tonnes of captured and stored carbon dioxide a year by 2030, and over 50 million tonnes/yr by 2035 to make the UK North Sea the main carbon storage hub for Europe. ? The North Sea Transition Authority on (CCS storage timing as above) [REDACTED] ? Great British Nuclear responsible for the planned roll out of home-grown technology and Small Modular Reactors (SMRs) on the timeframe and feasibility by 2030 or earlier. ? UK’s Rolls-Royce Ltd. the Home grown technology liscenced in the US base on 60 years of experience with small nuclear (or EDF) To Deliver Clean, Affordable Energy For All - Rolls Royce SMR [REDACTED] ? The UK Nuclear Industry Association on SMR technology status, performance and plan to fast track co-location of SMRs on existing and proposed large nuclear sites in the UK (with small footprints one tenth that of large nuclear, modular construction and fast approval and deployment). [REDACTED] ? The Nuclear Decommissioning Authority (NDA) as above on existing plans to coordinate decommissioning of lager nuclear with co-location of Small Modular Reactors (SMRs). ? Ofgem and National Grid would be very helpful in the consideration of alternatives and Rampion 2 in ths Examination for a number of NPS policies. In particular, to undertake system value modelling analysis with / without Rampion 2 and for alternatives. This can readily included modelling for parameters such as in the following list to enable the Examination Authority to have robust and less subjective consideration of relevant NPS policy on Alternatives, recognising once again Rampion 2 is a £ 3- 4 billion (irreversible) investment allocation decision. Modelling outputs, such as: ? System value (including for generation, and reducing investment in transmission and ancillary services) ? Capital Investment ? Energy generation quantum and quality (variability and dependable power output) ? Contribution to power system flexibility, reliability and operation (reducing outage risk) ? Co2 emission reduction / offsetting (domestic and offshored emissions in supply chains) ? Contribution to decarbonising the UK power sector by 2035 ? Contribution to UK energy security and reducing import dependency (including technology supply chains) ? Boost to UK business, high tech jobs and industrial strategy, including export ? The Crown Estates (CE) in respect to the alternative of adding wind turbines (those proposed for Rampion 2) to locations where RWE acquired two additional licences in January 2023 on the southern Dogger Bank and where project design has yet to proceed or is not advanced. ? Here we also note as background, Rampion 2 was tendered in the 2017 windfarm extension bid round where the bid criteria included the extension project could be no larger the existing windfarm (in this case Rampion 1 at 400 MW), though after the bid award Rampion 2 was increased to 1,200 MW. This optimistically suggests there is flexibility in the seabed licensing system and for negotiated outcomes in the Public Interest taking into account various economies-of-scale and opportunities for shared facilities in North Sea licence area by 2030. ? Also expert testimony on Crown Estate’s role in carbon capture and storage in south coast geological formations offshore near existing gas turbine facilities with potential CCS/ CCUS conversion in future, accepting that initially carbon storage by barge to the North Sea storage facilities may be required. The approach of inviting expert testimony that is needed for genuine and robust consideration of alternatives (as provided in NPS EN-1 cited earlier) hopefully is seen as reasonable. PINS Advisory Notes indicate that expert testimony is often requested and taken by the Examination Panel on topics the where individual Panel members may not have the background and expertise, such as especially where it is technology specific and in a landscape of rapid technology change.