Representation by National Grid Electricity Transmission plc (National Grid Electricity Transmission plc)
- Date submitted
- 13 June 2024
- Submitted by
- Other statutory consultees
Relevant Representation of NGET (National Grid Electricity Transmission Plc) in respect of the Outer Dowsing Offshore Windfarm DCO (the “Project”) This relevant representation is submitted on behalf of National Grid Electricity Transmission Plc (“NGET”) in respect of the Project, and in particular NGET’s existing and proposed infrastructure and land interests which will be located within and in close proximity to the proposed Order Limits. The Project proposes to construct 400kV cables from its onshore converter station, connecting to NGET’s proposed Weston Marsh Substation, which forms part of the Grimsby to Walpole (G2W) Project. The Applicant is seeking temporary and permanent rights over several plots, including those shown on page 51 of the Land Plans and referenced in the draft DCO as Work Number 17. As a responsible statutory undertaker, NGET’s primary concern is to meet its statutory obligations and to ensure that any development does not adversely affect those statutory obligations. NGET has a duty to protect its position in relation to infrastructure and land which is within or in close proximity to the draft Order Limits. Additionally, NGET must protect its future proposed infrastructure. NGET will therefore require appropriate protection for retained or proposed apparatus, including compliance with relevant standards for works proposed within close proximity of its apparatus or proposed apparatus. NGET’s rights of access to inspect, maintain, renew and repair such apparatus must be maintained at all times and access to inspect and maintain such apparatus must not be restricted. Further, where the Applicant intends to acquire land or rights, or interfere with any of NGET’s interests in land or NGET’s apparatus, NGET will require appropriate protection. Further discussion and agreement with the Applicant is required in relation to the impact on its apparatus and rights. NGET owns and operates two 400kV overhead lines that are located within and in close proximity to the Order Limits for the Project. These assets form an essential part of the electricity transmission network in England and Wales. The details of the electricity assets are as follows: • 4ZM 400kV OHL – Spalding North – Walpole; Bicker Fen – Walpole – West Burton • 2WS 400kV OHL- Bicker Fen – Spalding North – West Burton; Spalding North - Walpole • Associated cable fibres Furthermore, based on information currently available, NGET has identified potential interfaces between the Project and the proposed NGET infrastructure projects detailed below. These proposals are part of NGET’s Great Grid Upgrade – the largest overhaul of the grid in generations. NGET infrastructure projects across England and Wales are connecting additional renewable energy to homes and businesses. NGET must ensure adequate projection for its future projects both in terms of protection for future assets and future land and rights for the delivery of these projects. Co-operation Overarching National Policy Statement (NPS) for Energy EN-1 states that “[t]o support the achievement of the transition to net zero, government is accelerating the co-ordination of the development of the grid network to facilitate the UK’s net zero energy generation development” (para 4.11.3). This is reflected in the NPS for Renewable Energy Infrastructure EN-3 which states at paragraph 2.8.34 that “a more co-ordinated approach to offshore-onshore transmission is required.” In line with good practice and the new policy considerations in the updated Energy NPS’, particularly EN-5, which requires that “2.14.2 the construction planning for the proposals has been co-ordinated with that for other similar projects in the area on a similar timeline;”, NGET will continue to co-operate on co-ordination in respect of G2W and seek to develop co-ordination and co-operation in the same localities with regards to EGL 3 and 4. The Parties have been co-operating since 2021 in relation to G2W, meeting regularly to discuss such matters as respective delivery programmes, connection location, consultation timelines and coordination of temporary and permanent design. Whilst interaction between the Parties has so far been limited to two one-hour meetings on EGL 3 and 4, NGET wishes to develop this further. The Project interacts with the NGET projects set out below, both of which will be brought forward as DCOs. Eastern Green Link (EGL) 3 and 4 EGL 3 and EGL 4 are independent projects that are being developed in parallel. The EGL 3 and EGL 4 projects involve a mix of offshore and onshore development and consent for the English components will be sought under a single DCO. The projects are currently in the process of non-statutory consultation. EGL 3 and EGL 4 benefit from a section 35 direction which recognises the national significance of the EGL 3 and EGL 4 projects, and the EGL 3 and EGL 4 projects will seek development consent orders in due course. The EGL 3 and EGL 4 projects are recognised as being essential to the Country’s future energy security and meeting net zero targets. The EGL 3 project will be a new offshore High Voltage Direct Current (HVDC) electrical link from Peterhead to Walpole, Norfolk. EGL 4 will be a new offshore HVDC electrical link from east Scotland, also to Walpole, Norfolk. EGL 3 and 4 are needed as the existing transmission network does not have enough capacity to securely and reliably transport the increasing amount of energy generated in Scotland and Scottish waters, particularly from offshore wind, to population centres in the Midlands and South of England. There is a direct interaction between the Project and EGL 3 and EGL 4, with a crossing north of the river Welland in proximity to Fosdyke in South Holland where EGL 3 and 4 cables and Project cables intersect. Both projects are likely to be under construction at the same time and so cumulative effects on the area must be coordinated. The EGL 3 and EGL 4 projects are recognised as being projects of critical national priority under the National Policy Statements. It is therefore essential that the Project accommodates this interaction and that the protective provisions ensure that future working can be agreed between the parties and that there are no restrictions which would prevent this. Grimsby to Walpole The Grimsby to Walpole Project will establish a new 400kV transmission line of approximately 140km in length between Grimsby and Walpole, and five proposed substations, summarised below; • a new substation in the vicinity of the existing Grimsby West substation in North East Lincolnshire, • two new substations (notionally named Lincolnshire Connection Substations) located south-west of Mablethorpe in East Lindsey, • a new substation (notionally named Weston Marsh) in the vicinity of the existing 400kV Spalding Tee-Point, where the overhead lines denoted as 4ZM and 2WS meet, located in South Holland District, and • a new substation (notionally named Walpole B) in the vicinity of the existing Walpole substation, located in King’s Lynn and West Norfolk District. The connection is expected to wholly or largely comprise a new overhead line. NGET will also need to replace short sections of existing 400kV overhead line and commission local changes to the lower voltage distribution networks to facilitate the construction of the new overhead line and substations. These new substations are planned for offshore wind generation, battery storage/solar, interconnectors with other countries and subsea links to Scotland through high voltage direct current (HVDC) links. G2W will increase the capability of the network to carry clean green energy from the north of England to the Midlands and East Anglia. This is required due to existing power lines not having sufficient capacity for all the new sources of electricity expected to connect to the network over the next 10 years and beyond. The Project seeks the ability to compulsorily acquire rights over land within which the proposed Weston Marsh Substation will be constructed and to which the Project will connect. Weston Marsh Substation will be constructed as part of G2W. There may also be interactions between the two projects elsewhere. Protection of NGET Assets NGET will require Protective Provisions to be included within the draft Development Consent Order (the “Order”) for the Project to ensure that assets existing at the time of construction of the Project are adequately protected and to ensure compliance with relevant safety standards. NGET also requires that the Protective Provisions include protection for its future assets including the G2W, EGL 3 and EGL 4 projects. The Awel Y Mor DCO provides a precedent for the protection of future assets via Protective Provisions. NGET is liaising with the Applicant in relation to such Protective Provisions. Accordingly NGET has not appended the version of the Protective Provisions it requires to be included in the Order to this Relevant Representation. However, NGET will submit these at Written Representation Stage, if not agreed between the parties by that point, with an explanation of any outstanding issues. NGET requests that the Applicant continues to engage with it in relation to how the Applicant’s works pursuant to the Order (if made) will ensure protection for those proposed NGET assets, along with facilitating all future access and other rights as are necessary to allow NGET to properly discharge its statutory obligations. NGET will continue to liaise with the Applicant in this regard with a view to concluding matters as soon as possible during the DCO Examination and will keep the Examining Authority updated in relation to these discussions. Detailed discussions between the Parties during workshops have already eliminated potential issues relating to siting of the Weston Marsh Substation with regards to interactions with the G2W project. Compulsory Acquisition Powers in respect of the Project Where the Applicant seeks powers of compulsory acquisition over NGET land or rights, the Protective Provisions must require that the Applicant obtain NGET’s consent to any compulsory acquisition of any such land or rights. NGET reserves the right to make further representations as part of the Examination process in relation to specific interactions with its EGL 3 and 4 and G2W projects, or any NGET projects identified during the Examination process, and as negotiations continue, but in the meantime will continue to liaise with the Applicant from G2W and EGL 3 and 4 with a view to reaching a satisfactory agreement during the Examination process and will keep the Examining Authority updated in relation to these discussions.