Representation by Lincs Wind Farm Limited (Lincs Wind Farm Limited)
- Date submitted
- 13 June 2024
- Submitted by
- Non-statutory organisations
Lincs Wind Farm Limited (“Lincs”) owns and operates an operational offshore windfarm with a s36 consent and relevant marine licences (“Lincs Wind Farm”). Lincs wishes to register as an interested party. The Outer Dowsing Wind Farm array is proposed to be located 46.05km away but there is an overlap between the Lincs array area and the Projects 1km buffer around the offshore ECC. Lincs does not object to the principle of ODWF. We do, however, wish to participate in the DCO Examination to make representations about the potential impacts on and interactions with Lincs and, where appropriate, to secure appropriate mitigations and if deemed appropriate protective provisions due to the significant proximity between the projects. Lincs would like to engage with ODWF to discuss the inclusion of protective provisions in the DCO pending completion of a proximity agreement. For the avoidance of doubt Lincs agrees with ODWF that the overlap can be addressed through a proximity agreement but we expect further meaningful engagement to seek to address the overlap and the below issues which we are open to addressing within or outside the Examination process. Lincs expects to continue to operate and be maintained in the long-term. It may be upgraded and repowered in future and will then be decommissioned. Co-existence with Lincs must be considered and protected over the long-term. Lincs requires that its operations, consents (including conditions), and any stakeholder agreements entered into by it are unaffected by ODWF. As stated in the original s42 response, it would be helpful to understand all of the ODWF’s project components and routes associated with the proposed works (including the transmission works) so that we can establish that access for Lincs Wind Farm, including access for jack up vessels and anchor splays (etc.), will be maintained and that physical interactions can be avoided or understood and appropriately mitigated. Lincs concerns include the following but we reserve the right to raise additional concerns as appropriate: Issue one: The first point to note is the effect of energy yield upon Lincs. The proposed ODWF is approximately 46.05km from Lincs Wind Farm. Due to its proximity, there is significant potential for the ODWF turbines to interfere with wind speed or wind direction of Lincs and thus cause a reduction in energy output from the Lincs turbines. We note the response from ODWF that the Project has been sited in accordance with requirements of the Crown Estate’s Offshore Wind Leasing Round 4 process, including that projects may not be located within 7.5km of an existing offshore wind farm. We further note that this requirement is considered to mitigate against the potential for the proposed ODWF to impact the energy output from Lincs. This however does not negate the requirement for ODWF to engage on this issue and consider any evidence presented by Lincs. Issue two: It has been noted that Lincs has been assessed as a receptor for activity/access displacement in construction, direct disturbance and damage to existing assets from construction and disturbance to operations from the physical presence of infrastructure. For all areas the conclusion is not significant. We would appreciate if more information on this could be provided so we can properly understand and respond to the potential impacts and mitigations being proposed. It is important that any solutions properly take into account existing consent conditions and agreements. As noted above it would be helpful to understand all of ODWF’s project components and routes associated with the proposed works and how they interface with the Lincs Wind Farm. Issue three: In relation to shipping and navigation we would appreciate being given the opportunity to input into and participate in discussions around navigational risks. Lincs requires direct engagement both prior to and during construction. Once further information becomes available through examination and we have had the opportunity to consider the assessments in detail, Lincs may require protective provisions to ensure engagement prior to finalisation of ODWF’s construction programme due to the proximity/overlap between the projects. Issue Four: We note the potential for in-combination impacts on Kittiwake (where there is potential for AEoI (Table 12.1 of the RIAA). We further note that cumulative impacts in relation to ornithology and migratory fish has the potential to affect post construction monitoring of Lincs. We also note that within Document 7.6.3 the Applicant has proposed a SAC extension over Lincs’ export cable route. It is imperative that Lincs continues to be considered so operational requirements are not impacted. We wish to be kept informed as we may wish to respond to any questions from the Examining Authority or comment on responses submitted by the Applicant or others.