Representation by Hornsea 1 Limited (Hornsea 1 Limited)
- Date submitted
- 13 June 2024
- Submitted by
- Non-statutory organisations
Hornsea 1 Limited owns and operates an operational offshore windfarm with a Development Consent Order (DCO) and relevant marine licences (“Hornsea 1”). We wish to register as an interested party. Hornsea 1 is proximate to the proposed Outer Dowsing Offshore Wind Farm (“ODWF”). The ODWF array is proposed to be located 23.10km and its cable corridor 38.20km away from Hornsea 1. We refer you to our s42 consultation response dated 21st July 2023 (s42 response) that supplements this response. Hornsea 1 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 Hornsea 1 and, where appropriate, to secure appropriate mitigations. We expect further meaningful engagement to seek to address the below issues which we are open to addressing within or outside the Examination process. Hornsea 1 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 Hornsea 1 must be considered and protected over the long-term – and the acceptability of cumulative and in-combination impacts – must be properly assessed taking into account each of the above stages of Hornsea 1’s life. Hornsea 1 requires that its operations, consents (including conditions), and any stakeholder agreements entered into by it are unaffected by ODWF. Hornsea 1’s concerns include the following but we reserve the right to raise additional concerns. Issue one: The first point to note is the effect of energy yield upon Hornsea 1. The proposed ODWF is approximately 23.10km from Hornsea 1. Due to its proximity, there is significant potential for the ODWF turbines to interfere with wind speed or wind direction of Hornsea 1 and thus cause a reduction in energy output from the Hornsea 1 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 Hornsea 1. This however does not negate the requirement for ODWF to engage on this issue and consider any evidence presented by Hornsea 1. Issue two: Table 15.4 notes the routes used by vessels associated with the Hornsea Projects with reference to the Humber Ports as the route used by construction, operation and maintenance to the Hornsea Projects from the Humber. As part of our review of the PEIR we noted that vessel displacement and restriction of adverse weather routeing would be revisited once array reductions were applied. We note in the ES that a statement is made that vessels typically pass north of the Hornsea Project’s array areas and as such no impact is anticipated. Nonetheless the cumulative and in-combination effects as set out in the s42 response remain a concern due to the nature of the increased development in a congested area of sea. Issue three: 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 has the potential to affect post construction monitoring of Hornsea 1. It is imperative therefore that Hornsea 1 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.