Representation by Well Parish Meeting (Well Parish Meeting)
- Date submitted
- 10 June 2024
- Submitted by
- Non-statutory organisations
At the AGM of Well Parish Meeting held on Tuesday 7th May 2024, the Meeting voted unanimously to continue to Object to Outer Dowsing Offshore Wind (ODOW) on the following grounds: 1. CONFLICTS OF INTEREST The proposed project is 1.5GW output and can only connect to the 400kV system (The Grid). National Grid (NG) nominates where projects connect to The Grid. NG nominated two greenfield sites for ODOW, both close to the High Pressure Gas System (Alford and Surfleet). Macquarie Bank is one of the investors in ODOW. National Grid (NG) and Macquarie Bank co-own the UK gas transmission system. This conflict is undeclared. Macquarie Bank also has the right to buy out the remaining NG interest in the Gas Transmission System. This is undeclared. We believe ODOW has been designed around the location of an undisclosed Hydrolyser plant to manufacture hydrogen to substitute methane in the gas transmission system. This would benefit both NG and Macquarie Bank. Also, ODOW have nominated and designed for Alternating Current (AC) generation at an export voltage of 275kV. This choice necessitates onshore step-up transformers (275kV to 400kV); an onshore substation (OnSS), and the probable need for an onshore reactive compensation station (OnRCS). Cable reach for 275kV AC is limited without accommodating for reactive power (losses). Connecting ODOW’s 1.5GW at Walpole into the B9 boundary, which is already spilling largely renewable generation, further overloads the carrying capacity of The Grid in that area and contributes to the need for NG’s Great Grid Upgrade (GGU). Two sizeable projects (Triton Knoll @0.875 GW and Viking Link @2.2GW), have already been added at Bicker Fen where there is no local electrical demand. When we asked NG employees at a ‘information day’ why all these inter-dependent projects i.e. the GGU infrastructure, renewable generation and interconnectors (all planned for completion around 2030), were not combined into one DCO Application, they told us ‘it would never be consented’. 2. EXTENT OF THE PROJECT In the Scoping report and at the Old Leake consultation, project members for ODOW stated there would be material Additional Associated Development (Hydrolyser Plant and Storage). Neither of these is detailed in the PIER or the ES. However, in their DCO Application, ODOW state an indicative site area of 240,000m2 (c.59 acres) of prime agricultural land for their OnSS. Even allowing for flood risk mitigation, this area is excessive for two 275kV to 400kV transformers. However, it would accommodate a Hydrolyser Plant and/or Battery Storage. Surfleet is close to the HP gas system and a water supply. No water and/or no HP gas system, no Hydrolyser Plant. The proposed (if needed) Onshore Reactive Compensation Station (OnRCS) has an indicative height of 25m. The need for, and site, of this has not been confirmed. If it were outside the Surfleet Marsh OnSS site, further consultation and impact assessment would be required. 3. FLOOD RISK ODOW is reliant on connection to The Grid at an NG substation at Walpole (part of the Grimsby to Walpole section of the GGU). This NG substation does not yet exist. Both the site of this proposed NG OnSS, and the ODOW OnSS at Surfleet are in designated Flood Risk areas. ODOW’s OnSS is sited in Flood Zones 2&3 but is deemed to have passed the Exception Test (EN-1 para.5.8.11). However, the project would only provide ‘wider sustainability benefits’ to the community (Part 1 of the Exception Test), if ‘net zero by 2050’ were achieved globally. Raising the OnSS and associated equipment 300mm above peak modelled flood level would be extremely expensive and the modelling does not appear to include the possibility of a storm surge up the Wash coinciding with (or causing), the collapse of the existing flood defences. Pylons can cope with flooding; transformers and hydrolyser plants cannot. Making a project a NSIP does not make it immune to flooding. 4. LOWER COST OPTIONS/COMPLIANCE WITH HND Objective 1 of the Holistic Network Design is ‘cost to consumer’. ODOW is backed by the taxpayer through a CfD with OfGem. Any SoS has a duty to ensure taxpayers receive Value for Money. National Grid is a regulated monopoly supplier of high voltage electrical transmission, whose duty is to its shareholders. The lowest cost cabling connection for ODOW (as currently configured in this Application) would be up the Humber. The overall cabling length would be shorter and there would be less onshore cable burial. However The Humber has been ruled out under the ONTR. Connecting ODOW at Walpole contributes to the requirement for NG’s GGU, as it is being landed in an area already saturated with renewable generation and consequently spilling power, predominately south. Southern England is a massive power sink with a deficit of around 23GW. National Grid is incentivised to connect generation far from demand as this necessitates more onshore infrastructure, increasing NG’s profits. The cost of the HND/GGU ultimately falls on the consumer due to the apparent failure of the UK to organise generation where power is actually needed. The costs in disruption and loss of amenity etc. are borne by local communities, most of which do not benefit from the project. Burying HVAC cables offshore costs c£4MM a kilometre. Burying HVAC onshore costs c£10MM per kilometre. As proposed in this DCO Application, ODOW require 4 circuit 275kV cables of which 77kms is offshore and 63kms are onshore. This is a relatively short distance for offshore cabling, so the largely fixed costs of mobilisation and demobilisation of the cable-laying barge are spread over a low number of kms, increasing the cost per kilometre of the offshore portion. Removing the undeclared Hydrolyser Plant and Storage means that ODOW would become what it purports to be: an offshore generation project in need of connection to the Grid. There is then no need for landfall on the Lincolnshire coast, or connection to the Grid at Walpole. ODOW could export HVAC (400kV), removing the need for its OnSS and OnRCS. Without onshore cabling, ODOW could lay a total of c.240kms of offshore cabling (at the same cost). Cabling from ODOW offshore to Sizewell would be c170km in length. If ODOW generated HVDC (rather than HVAC), the cabling length (for the same cost), would reach Southend (some 240kms). More importantly, ODOW could contribute 240 kms of HVDC cabling to an offshore Grid, thus enabling power to be landed in Southern England; contributing to filling the 23GW sink; removing the need for the Great Grid Upgrade (at an overall lower cost), and saving the taxpayer money. However, National Grid would not earn any money out of an offshore Grid. Another undeclared conflict of interest. We believe this whole project has been configured for the benefit of NG and Macquarie Bank, to the detriment of the consumer and local communities, contrary to the objectives of the HND. 5. ROLES OF PINS AND SoS If ODOW and National Grid want to continue with the current arrangement under the DCO, both Macquarie Bank and National Grid should be requested to declare their conflicts of interest; detail their Additional Associated Developments clearly, and repeat all the consultation process in a transparent manner so that all third parties can review and comment on the real project. If ODOW and NG declare that they do not want now (or in the future), to incorporate a Hydrolyser Plant or Storage, there is no need to export 400kV to Walpole. The cost savings to the taxpayer should be assessed for offshore generation at 400kV+ with offshore cabling to Sizewell. If the Sizewell export system can carry the extra 1.5GW from ODOW without capacity reinforcement, and there are no actual technical reasons for such a connection, then this should be pursued as a lower cost option for the taxpayer. If the Sizewell system is constrained, then ODOW should be held back and integrated with the other new planned offshore generation and interconnectors into a HVDC offshore Grid, making landfall in Southern England. This would be the lowest cost, least disruptive option. The SoS should be accountable for facilitating this.