Representation by Race Bank Wind Farm Limited (Race Bank Wind Farm Limited)
- Date submitted
- 13 June 2024
- Submitted by
- Non-statutory organisations
Race Bank Wind Farm Limited (“Race Bank”) owns and operates an operational offshore windfarm. ODWF array is proposed to be located 23.50km away but there is an overlap between the Race Bank array area and ODWF’s 1km buffer around the offshore ECC. Race Bank does not object to the principle of ODWF. We wish to participate in the Examination to make representations about the interactions with Race Bank and, where appropriate, to secure appropriate mitigations and protective provisions due to the overlap. Race Bank would like to engage with ODWF to discuss the inclusion of protective provisions in the DCO. For the avoidance of doubt Race Bank agrees that the overlap can be addressed through a proximity agreement but we expect meaningful engagement to seek to address the overlap. Race Bank 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 Race Bank must be protected over the long-term. Race Bank requires that its operations, consents and any stakeholder agreements entered by it are unaffected by ODWF. As stated in the s42 response, it would be helpful to understand all the ODWF’s project components so that we can establish that access for Race Bank Wind Farm will be maintained and that physical interactions can be avoided or understood and appropriately mitigated. Race Bank’s concerns include: Issue one: The proposed ODWF is approximately 23.50km from Race Bank. Due to its proximity, there is significant potential for the ODWF turbines to interfere with wind speed or wind direction of Race Bank and thus cause a reduction in energy output from the Race Bank 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. This however does not negate the requirement for ODWF to engage on this issue and consider any evidence presented by Race Bank. Issue two: It has been noted that Race Bank 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. Further engagement is required in this regard. Issue three: Race Bank requires direct engagement both prior to and during construction relating to navigational risks. Once further information becomes available Race Bank 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: With regard to Radar we note the approach as outlined in the assessment but we are not clear as to whether you have considered the existing radar mitigation solutions which are in place to ensure they are not adversely affected. Issue Five: We note that within Document 7.6.3 the Applicant has proposed a SAC extension over Race Banks export cable route. It is imperative that Race Bank’s operational requirements are not impeded. Further engagement is therefore required on this issue.