Back to list Rampion 2 Offshore Wind Farm

Representation by Aquind Limited (Aquind Limited)

Date submitted
6 November 2023
Submitted by
Members of the public/businesses

RAMPION 2 OFFSHORE WIND FARM RELEVANT REPRESENTATION BY AQUIND LIMITED 1. INTRODUCTION 1.1 AQUIND Limited (AQUIND) are the promoter of AQUIND Interconnector, a proposed bi-directional electricity interconnector with a nominal capacity of 2000MW between Great Britain and France located off the coast of Portsmouth offshore and between Portsmouth and Lovedean substation onshore. 1.2 A development consent order is being sought to authorise the construction and operation of AQUIND Interconnector. A decision on whether to grant development consent for AQUIND Interconnector is awaited from the Secretary of State for Energy Security and Net Zero. 1.3 There is overlap of the Order limits for AQUIND Interconnector by the Rampion 2 Offshore Wind Farm (OWF). The purpose of this Relevant Representation (RR) is to outline the main issues which AQUIND identifies are required to be considered as part of the examination of the OWF in relation to that overlap, of information which has been identified to be required to be produced by Rampion Extension Development Limited (RED) in connection with the examination, and of the measures which are required to ensure that both projects are able to be delivered. 2. SUMMARY OF MAIN ISSUES 2.1 There is a lack of consideration of AQUIND Interconnector, including as part of the Alternatives (ref: APP-044 6.2.3 Environmental Statement - Volume 2 Chapter 3 Alternatives) and Proposed Development (ref:APP-045 6.2.4 Environmental Statement - Volume 2 Chapter 4 The Proposed Development) Environmental Statement (ES) Chapters. There is no reference to or consideration of the spatial overlap between the two projects. There is no genuine consideration of the proximity agreements and cable crossings required, and RED propose to designate a disposal site which spatially overlaps one of the AQUIND registered disposal sites and which has the potential to give rise to impacts which are not assessed. 2.2 The assessment of AQUIND Interconnector (as a receptor) in the Other Marine Users Chapter (ref: APP-048 6.2.7 Environmental Statement - Volume 2 Chapter 7 Other marine users) does not adequately consider the full range of impacts. Where impacts on AQUIND interconnector are assessed they are often undervalued or do not include consideration of the full extent of impacts to AQUIND. 2.3 The Other Marine Users Chapter also relies on mitigation which is either not adequately defined or developed (e.g. reference to cable crossings and proximity agreements but without required engagement or consideration), or that may result in impacts to AQUIND Interconnector itself (e.g. reliance on Safety Zones will restrict access to AQUIND Interconnector during construction and operation). 2.4 The cumulative effects assessment is not sufficient to identify all potential impacts on AQUIND Interconnector and in-combination with it. 2.5 There are not adequate provisions in the draft DCO to provide protections for AQUIND Interconnector. It is necessary to include protective provisions within the DCO for the OWF for the benefit of AQUIND Interconnector, in the interest of ensuring both projects can be delivered without giving rise to unacceptable impacts. 3. RESPONSE TO SCOPING OPINION AND GENERAL COMMENTS ON PROJECT CONSIDERATION 3.1 By way of background information, AQUIND Limited has previously commented on the scoping report submitted for the OWF on 3 August 2020 and in response to statutory consultation for the OWF on 16 September 2021. Specific items raised by AQUIND in those responses were as follows: 3.1.1 advising RED to engage further with AQUIND to inform the project design evolution for the OWF (which was based on an area of search for the OWF Array Area at the time); 3.1.2 advising that AQUIND would expect RED to consider suitable standoff distances between AQUIND Interconnector cables, and as infrastructure is within 1 nautical mile (NM) of AQUIND Interconnector it was requested that RED fully engage to understand the implications; 3.1.3 reiterating the need for RED to consider AQUIND Interconnector at an early stage of the project design and to adequately consider the AQUIND Interconnector project from a cumulative effects assessment perspective as part of their offshore application and supporting assessment; and 3.1.4 making clear that the proposed project boundary for RED overlapped with the Order limits for AQUIND Interconnector and the registered disposal sites. 3.2 Despite providing constructive feedback to RED and making clear the importance of considering the overlap of the two projects and ensuring that the assessments undertaken to support the OWF adequately assess AQUIND interconnector: 3.2.1 there has been no engagement by RED in relation to the overlap of the OWF with the Order limits for AQUIND Interconnector; 3.2.2 it is apparent that despite Scoping Report for AQUIND Interconnector being submitted to PINS in 2018, the DCO application submission in November 2019, and the designation of two disposal sites (WI048 and WI049 which are referred to as AQUIND Site A and B respectively in the RED application) in connection with the construction of AQUIND Interconnector, no consideration of AQUIND Interconnector, including spatial overlap of the OWF and the Order limits for AQUIND Interconnector, has been made as part of the site design and the consideration of alternatives for the OWF. 3.3 Accordingly, it is identified that there has not been adequate engagement with AQUIND or consideration of AQUIND Interconnector as part of the application for a DCO for the OWF, or moreover in the consideration of alternatives and the design evolution of the OWF, with little to no acknowledgement of the overlap by the OWF of the Order limits for AQUIND Interconnector. 4. CLARIFICATIONS IN RESPECT OF THE OVERLAP OF AQUIND INTERCONNECTOR 4.1 In general, there is a lack of detail provided on the location of the OWF project infrastructure in the Offshore Array Area, including location of Wind Turbine Generators (WTGs), offshore substation platforms (OSPs), and cables (array and export cables). 4.2 There is also no consideration of the presence and overlap with AQUIND Interconnector within the Description of Development Chapter of the ES (ref: APP-045 6.2.4 Environmental Statement - Volume 2 Chapter 4 The Proposed Development), where the only mention of AQUIND Interconnector is that the project is subject to redetermination and that should cable crossings be required a methodology will be agreed with the relevant owners. 4.3 For the avoidance of doubt, there has been no approach to AQUIND by RED in relation to any such agreement to date. 4.4 A summary of the extent of and key points identified in relation to the overlap of AQUIND Interconnector is as follows: 4.4.1 It is identifiable from the Offshore Works Plans (ref: APP-008 2.2.1 Offshore Works Plans) that there will be an overlap of AQUIND Interconnector direct current cable corridor and disposal site WI048 by OWF Work No. 1 – 4, which includes WTGs, OSPs, array, and export cables. 4.4.2 There is currently inadequate detail regarding the layout or location of WTGs within the array, and no acknowledgement of AQUIND Order Limits. This is identified to be an omission from the information that has been submitted that should be addressed through updates to the application. 4.4.3 In AQUIND's view there should be design measures / principles secured noting the presence of AQUIND Interconnector. There should also be consideration of, and reference to, required proximity agreements to ensure minimum distances between WTGs (and OSPs) and AQUIND Interconnector is in line with relevant guidance (e.g. European Subsea Cables Association (2016) Guideline No.6 – The Proximity of Offshore Renewables Energy installations & Submarine Cable Infrastructure in UK Waters (which advises any proposed development within 1 NM of subsea cables requires discussion on separation distances with the aim to agree mutually acceptable proximity agreements)). In the absence of suitable engagement and agreement on this matter we identify that a 1 nautical mile separation distance is necessary to ensure there is certainty both projects can be delivered and operate safely. 4.4.4 There is a lack of detail on the proposed seabed preparation activities, methodologies for and the location of works, including more particularly in respect of: (A) methodology for clearance e.g. mass flow excavator (MFE), trailing suction hopper dredger (TSHD) etc.; (B) locations of clearance, even if indicative locations; (C) method and locations for disposal of dredged material; and (D) any consideration of AQUIND Interconnector in connection with such activities, including the two registered disposal sites located in the DCO Order Limits. 4.4.5 The proposed OWF disposal site (being the whole of the Offshore Array Area) directly overlaps with AQUIND Interconnector, including Disposal Site A (WI048). This overlap should not be permissible with other existing registered disposal sites and interconnector projects, and the proposed OWF disposal site boundary should be amended to avoid AQUIND Interconnector plus a suitable buffer. 4.4.6 Coupled with the lack of adequate consideration of AQUIND Interconnector as a receptor in the Other Marine Users Chapter of the ES (Ref: APP-048 6.2.7 Environmental Statement - Volume 2 Chapter 7 Other marine users), there is significant risk that the OWF may significantly impact on the construction and operation of AQUIND Interconnector and that this impact is not yet clearly identified and mitigated. 4.4.7 The OWF application proposes to include Safety Zones (SZs) of 500m and 50 m around WTGs and OSPs, which would prevent access during construction, O&M and decommissioning phases of AQUIND Interconnector, where overlapping with it. There is no detail on the location of the OWF infrastructure, and as such it currently must be assumed that as a worst case that impact will occur. 4.4.8 The number of cable crossings required in connection with the OWF is estimated by RED to be four for the Inter Array Cables (IACs). However, is it not clear how this has been calculated and what assumptions this is based on. Nor is it clear if the proposed crossing parameters are adequate for the number and nature of the crossings required. There is a risk that RED will not have considered an adequate number or size of crossings to facilitate all crossings required where the AQUIND Interconnector cables and IAC are crossed. 4.5 Noting the paucity of information regarding the OWF and how the infrastructure and operations to construct this may overlap with AQUIND Interconnector, AQUIND is concerned that RED have not sufficiently considered AQUIND Interconnector and how the OWF may be delivered without adversely impacting the construction and operation of AQUIND Interconnector. 4.6 Further information on the consideration of AQUIND Interconnector (or lack thereof) is detailed in the below section, which focuses more specifically on the Other Marine Users chapter of the ES (ref: APP-048 6.2.7 Environmental Statement - Volume 2 Chapter 7 Other Marine Users) 5. CONSIDERATION OF AQUIND AS A MARINE USER 5.1 AQUIND is considered within the Other Marine Users chapter of the ES (ref: APP-048 6.2.7 Environmental Statement - Volume 2 Chapter 7 Other marine users), however the assessment is not identified to consider AQUIND Interconnector adequately for the following reasons: 5.1.1 AQUIND Interconnector is considered as three different developments – interconnector cables, and two disposal sites. This results in the potential to undervalue the possible impacts on AQUIND Interconnector by considering the development in a piecemeal fashion rather than as a single project. 5.1.2 Not all potential impacts on AQUIND Interconnector have been considered (see further info provided below). 5.1.3 In some instances, impacts which have been considered have largely undervalued the magnitude of the impact and the sensitivity of AQUIND Interconnector to them. 5.1.4 There is reliance on embedded mitigation which is not effective and / or adequately secured in the draft DCO. 5.2 The following is a summary of specific issues identified in connection with the Other Marine Users Chapter: 5.2.1 Baseline – there is a failure to consider AQUIND B Disposal site, along with site A, which has potential to be adversely impacted. 5.2.2 The Maximum Design Scenarios (MDS) fail to consider cable crossings. It is imperative that cable crossings and the possible interactions with AQUIND Interconnector are assessed and impacts and mitigations required in relation to those are identified and secured. 5.2.3 In respect of embedded mitigation: (A) It is noted that "Crossing and proximity agreements with known existing pipeline and cables operators will be sought" (see mitigation C50 in Table 7-13 in APP-048 6.2.7 Environmental Statement - Volume 2 Chapter 7 Other marine users). There is a lack of provisions in the draft DCO to adequately secure the need for such agreements, and also to ensure that AQUIND is consulted on key documentation e.g. cable installation plans, construction method statements etc. (B) It is also noted that "RED will apply for Safety Zones post consent. Safety Zones of up to 500m will be sought during construction, maintenance and decommissioning phases. Where appropriate, guard vessels will also be used to ensure adherence with Safety Zones or advisory passing distances, as defined by risk assessment, to mitigate any impact" (see mitigation C56 in Table 7-13 in APP-048 6.2.7 Environmental Statement - Volume 2 Chapter 7 Other marine users). As identified above, this 'mitigation' may unacceptably impact AQUIND Interconnector due to the overlap, and because SZs being present may prevent access to AQUIND Interconnector during construction, operation and decommissioning. 5.2.4 There are a number of impacts on AQUIND interconnector which are absent from the assessment and should be included, being: (A) the potential damage to AQUIND Interconnector and / or interaction between the two projects during all phases of development; and (B) the displacement or prevention of access to AQUIND Interconnector during all phases of development. 5.2.5 Where impacts have been assessed (e.g. increased traffic, displacement from SZs, physical presence of infrastructure and temporary increases in suspended sediment concentration (SSC) and deposition) it is considered that the magnitude of the impact and the sensitivity of AQUIND Interconnector to the impact is understated, and that the significance of the impacts is understated as a result. This appears to derive from the lack of proper consideration of the spatial and temporal overlap between AQUIND Interconnector and the OWF, and the failure to consider AQUIND Interconnector and its two disposal sites as a single project. 5.2.6 There are potential impacts on AQUIND Interconnector as a consequence of SSC and deposition which should be assessed, and the absence of assessment provides significant concern that the effects of SSC and deposition have not adequately been considered. As disposal activities in connection with the OWF overlap directly with AQUIND Interconnector the following impacts should also have been included as part of the EIA: (A) The impacts resulting from disposal of material by RED in the AQUIND Interconnector DCO Order limits. (B) Any harder or consolidated material deposited by RED (e.g. drill arisings) in the AQUIND Interconnector DCO Order limit having the potential to impact directly on the AQUIND Interconnector cables. (C) Increasing depth of cover on the AQUIND Interconnector cables resulting in potential overheating of cables. 6. COMMENTS ON CUMULATIVE EFFECTS ASSESSMENT 6.1 In addition to the comments detailed above regarding the consideration, assessment of impacts on and mitigations required in relation to AQUIND Interconnector, AQUIND has also considered the approach taken by RED to the assessment of cumulative effects, including the in-combination assessment undertaken to satisfy the requirements of the Conservation of Habitats and Species Regulations 2017. 6.2 It is identified that there are several deficiencies in relation to the cumulative effects assessment, and in relation to the manner in which AQUIND Interconnector is considered cumulatively with the OWF. 6.3 As a general overview in connection with the marine topic chapters in the ES: 6.3.1 Information used for the assessment in relation to AQUIND Interconnector is not current in certain instances. 6.3.2 As noted above, despite being a single project AQUIND Interconnector has been split into three projects, which is not correct and risks undervaluing AQUIND Interconnector and the impacts on it. 6.3.3 Cumulative effects are often screened out as not being cumulative effects without adequate rationale or justification, including because of reliance on mitigation which is not robust or adequately secured. 6.3.4 A number of marine topic chapters do not consider AQUIND Interconnector from a cumulative perspective, despite clear temporal and spatial overlap. 6.3.5 It is often not clear why impacts assessed for the project are not carried through to the assessment of cumulative effects. 6.4 As a general overview in connection with the in-combination assessment undertaken to satisfy the requirements of the Conservation of Habitats and Species Regulations 2017: 6.4.1 Despite the in-combination assessment referring to Appendix 5.4 (ref: APP-128 6.4.5.6 Environmental Statement – Volume 4 Appendix 5.4 Cumulative effects assessment shortlisted developments), there does not appear to be any consideration of AQUIND Interconnector disposal sites activities. The only reference (coded as AQI) to AQUIND Interconnector is relevant to the interconnector cables and not to dredge and disposal activities. There has been no clear consideration of dredge and disposal activities in-combination with AQUIND Interconnector. 6.4.2 The consideration of AQUIND Interconnector does not consistently use updated information based upon re-submission of documentation for the project in connection with its redetermination. As a worst case scenario assessments should be updated based upon the assumption that the construction period of AQUIND and OWF could overlap. 6.5 AQUIND and its appointed consultants proposes to provide more detailed comments in this regard to RED, so that they may update their assessment during the course of the examination for the OWF. 7. CONCLUSION 7.1 In light of the issues identified AQUIND's current position must be that it objects to the grant of a DCO for the OWF, and this holding objection is issued on this basis. The issues identified must be addressed, so that the assessment of impacts on and in-combination with AQUIND Interconnector is sufficiently robust, and mitigation necessary in relation to those impacts must be clearly secured. This should then allow for this holding objection to be confirmed to be withdrawn. 7.2 AQUIND is willing to engage with RED to address the issues which have been identified in this RR in the shortest possible timescale, noting the benefit of this for the examination of the application. their is also noted that RED representatives have contacted AQUIND very recently following the submission of the OWF application, and an online meeting is being scheduled between AQUIND and RED for later in November 2023. 7.3 AQUIND is also willing to engage with RED on the form of protective provisions which are required to be included in the DCO for the OWF for the benefit of AQUIND interconnector. 7.4 Should it assist the Examining Authority, AQUIND is willing to engage with RED to produce a Statement of Common Ground and Principal Areas of Disagreement Statement, so that the Examining Authority has a clear record of the issues relevant to the overlap of AQUIND Interconnector by the OWF and of the position in relation to relevant matters as the examination progresses.