Representation by Andrea Simmons
- Date submitted
- 6 November 2023
- Submitted by
- Members of the public/businesses
My registration comment is to reinforce calls for the Examination Authority (ExA) to request or advise the Secretary of State for Energy Security and Net Zero (DESNZ), to whom the ExA will submit its recommendations, that there is a reasonable case to consider suspending the Rampion 2 Examination now while National Policy Statements are under review: - This may be in consultation with the Planning Inspectorate, as appropriate. - As discussed in our community a temporary suspension of an Examination during a NPS Review is provided for under the Planning Act (2008) Section 105. - For relevant context, this is considering: (1) the NPS update public consultation closed in mid-June 2023, where a new critical national priority (CNP) provision was added to only entertain offshore wind schemes as a critical national priority, and (2) in August 2023, ironically the 4th UK offshore wind bid round administered by The Crown Estates failed to attract a single international bidder. - The previous UK bid round only attracted European state-backed or supported consortium and mainly international financers seeking a high rate of return. - This suspension or pause in the Rampion 2 examination is thus both reasonable and necessary for many reasons in the Public Interest, including the confusion around the commercial Applicant’s respect for Section 51 Advice issued by the UK Government’s Planning Inspectorate (PINs). - Many residents who would be directly impacted and adversely affected, as potential “host communities” along the South coast, see this suspension or "pause" in the Examination as a substantive issue that needs to be resolved our interest and in the wider Public Interest. - This refers firstly, to the PINS Section 51 Advice Letter issued to the Rampion 2 Applicant RWE 10 Sept 2023 when the Application was accepted for Examination (essentially conditionally) requiring the Applicant to complete certain tasks before the Applicant called for registration of Interested Parties, which the Applicant categorically rejected and opened Registration 20 Sept 2023, with no regard to the S51 Advice. - Secondly, the PINS Section 51 Advice Letter to Protect Coastal Sussex in response to a question on suspending the Examination in the Public Interest until the NPS (2023, is in effect) and highlighting the confusion and controversy impacting on the Examination. - The advice that PINs offered to PCS was that the 12 year old NPS (2011) remain in effect for the Examination. Thus the NPS (2023, update) will not factor in the Examination. - Nonetheless, the Secretary of State for Energy Security and Net Zero can still apply the proposed CNP policies (NPS, 2023 proposed) even if they are not adopted at a later stage in deciding the Rampion Application and after the Examination Report is submitted. . In this comment we share affected Residents’ concerns that the recalibration of the NPS (2023, proposed) is possible, even likely. We argue the matter is highly relevant to the Rampion 2 Examination as it materially impacts on Interested Party inputs to the Examination. As argument and justification and in support of the Examination Authority raising this matter (suspending the Examination while the NPS is under Review as per Section 105 of the PA(2008)) with the Planning Inspectorate and Secretary of State as appropriate, as a matter of urgency. We extract the following input to the NPS (2023) consultations submitted mid-June as the point of reference. Extract: PCS Summary Note - Recommended Amendments to the Government’s proposed Critical National Energy Priority (CNP) - June 2023 Summary Note “Consultation Audiences: “The government wants to hear from members of the public, industry, non-governmental organisations and any other organisation or public body.” https://www.gov.uk/government/consultations/planning-for-new-energy-infrastructure-revisions-to-national-policy-statements Evidence suggests that limiting the UK’s critical national energy priority (or CNP) to offshore wind alone is counterproductive and requires amendment. Any CNP must also ensure that in parallel, complementary low-emission generation and other essential system components are in place to back-up the intrinsically intermittent offshore wind. That is essential to deliver secure, reliable and affordable electricity supply, as well as foster the achievement of sustainable development in affected coastal and inland areas all around these islands – not undermine it. This CNP approach actually increases UK dependency on imported energy and imported RE technology - at least for decades. For the foreseeable future the lion’s share of the UK’s offshore wind technology will be supplied by European commercial consortiums where the high-value green jobs, renewable subsidy and profits flow. It does little to advance home-grown energy technology, industry to support UK energy security and self-reliance, or advance UK global leadership to help other countries on their low emission journeys. ? As formulated the CNP spectacularly fails to take account of policy and regulatory failures over past decades that have placed “too many energy eggs” in one basket and has made UK electricity unaffordable for many households and small businesses today. ? Ironically, the UK is now saddled with the highest electricity bills in Europe, despite having the largest share of wind and solar of any major economy in the world, now approaching 50 percent on an average annual basis, ignoring the variability and intermittency. ? Military threats to all energy infrastructure fixed offshore, including wind installations, have not receded after 2022-2023 events and given geopolitical realignments now underway. In terms of promoting National Security CNP claims may be seen as wishful thinking, even reckless. ? It may also be argued this single technology focus is London-centric as directly harmful impacts are “out of sight, out of mind”. It assumes that all offshore wind projects have the same benefit-risk tradeoffs, thus can be imposed on coastal and inland communities simply by restricting time and local voice in the consenting processes, regardless of location and “residual impacts”. ? Most concerning is this CNP formulation ignores key recommendations of national and international bodies who have deeply considered the UK’s energy priorities and ways to effectively deliver decarbonisation of the power sector by 2035, and eventually NetZero, notably: ? The Parliamentary Committee on Climate Change in their recent report of March 2023 calling for an “equal focus to low-carbon flexible solutions as to the delivery of its existing renewable and nuclear commitments”; ? Ofgem and ESO statements on priorities to maintain reliable and affordable electricity supply as the share of variable RE is grown while the national grid comes under pressure from electrification mandates for transport and heating, at least doubling demand by 2035-2050; ? The World Bank Energy Sector Management Assistance Programme (ESMAP) and IEA, both advising on ways to responsibly integrate variable RE into electric power grids; ? The CBI urging Government to prioritise new nuclear power and scale-up carbon capture technology for flexible generation to power a competitive economy and reach NetZero; and ? The European Commission in 2022 which urgently classified natural gas and nuclear as green energy sources essential for the multi-decade transition (to unblock ESG financing). It may be reasonably argued that this CNP reflects the same “wilfully blind” thinking and narrative that landed the UK in the present-day mess: lots of variable RE generation (sometimes, and more to come) yet among the highest electricity bills in the world; leaving these islands more vulnerable to volatile international markets and supply chains for both imported RE technology and raw energy (i.e. LNG imports and gas pipelines and power interconnects with the continent). A more balanced and responsible way forward is to amend this CNP, namely by: i. Including clean, low-emission generation systems under the CNP umbrella to complement weather-dependent variable wind and electrification mandates, specifically flexible generation from abated gas-fired power (adding carbon capture to existing power stations to make them NetZero) and deploying small modular reactors (SMRs) in locations where existing large nuclear plant are decommissioned, as already provided in technology-specific NPS, but with no real sense urgency or priority; ii. Focusing offshore wind development in the designated Renewable Energy Zone (REZ) wisely identified as such in the UK Energy Act (i.e. from 12 to 200 nautical miles seaward); iii. Giving legal status to the Government’s own existing Offshore Energy Strategic Environmental Assessment (OESEA) advice on ensuring visual buffers for large wind turbines (distance from significant receptors, or from shore) to ensure consistency, fairness to coastal communities and thereby reduce controversy; iv. Ensuring system value analysis / modelling of all NSIP offshore windfarm proposals are routinely undertaken by relevant authorities (such as Ofgem or ESO) to inform each DCO application and to optimally time and sequence low-emission generation additions with the essential transmission and ancillary services; and v. Rank and prioritise locations to systematically promote investment in offshore wind by appropriate criteria such as efficiency, energy performance, system fit and value for money. Further it will massively help to introduce a fast track category of offshore wind developments that satisfy simple location and policy criteria, as suggested herein (in the PCS main consultation response). These proposed amendments are common sense and reflect considered advice of the bodies noted above. They are prudent and measured given the Government’s ambition is to collapse the consenting process for offshore wind from the present average of 4 years to 1 year, in effect by removing safeguards, close scrutiny and local voice - contrary to the wisdom of the Localism Act.