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Advice to John Pennington

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Enquiry

From
John Pennington
Date advice given
25 May 2023
Enquiry type
Email

For the Attention of Developers and The Planning Inspectorate In response to the current notices for the proposed projects listed below, I am pleased to submit this objection to the developers. This is also addressed to the Planning Inspectorate for their attention and response, regarding the application of the principles of the Rochdale Envelope. My concerns relate to the geographical extent of the proposed wind farms and the adverse impact on navigation. -Mona Statutory Notice -Morgan Offshore Generation Assets Statutory Notice -Morecambe Offshore Generation Assets Statutory Notice -Morgan and Morecambe Transmission Assets Adverse Impacts on Navigation My objection regarding the adverse impacts of the above proposed developments on navigation refers in particular to the Isle of Man's lifeline ferry services. The Planning Inspectorate's website for Morgan Offshore Generation Assets, 10 October 2022, records the following communication from the Maritime and Coastguard Agency. ''... I want to raise an early concern that (1) the three projects present concerns to safe navigation in the area and (2) I believe that separate planning applications would not provide a full representation of the impacts because of the risks they present cumulatively which probably most concern the MCA and other navigational stakeholders.'' The documents for the current proposals appear to show that the geographical extents of the schemes have not materially changed since the MCA expressed their concerns. Despite communications between the shipping interests and developers, I understand that the boundaries for the areas proposed for development remain a matter of concern for shipping operators, including the Isle of Man Steam Packet Company. Geographical Extent of Proposed Wind Farms Past experience shows that it is legitimate and reasonable to question the derivation of the geographical extent of the licence areas and of the actual development areas to be occupied by each of the proposed wind farms. The Crown Estate appears to define the licence areas with scant regard for navigation, and expects developers to thrash it out themselves. For example, the former (and subsequently abandoned) Rhiannon offshore wind farm licence area extended into and obstructed the established defined separated shipping lanes round Anglesey. Also, the Estate's defining Mona and Morgan as contiguous would clearly have resulted in a very major obstacle to navigation. The licence development areas are not set in stone, for example as demonstrated by the developer proposing to adopt less than the full licence area for development of Mona. A Request For More Information on Wind farm Extent and Layout Currently, there is free navigation over the whole area of the proposed wind farms. The custodian of the sea bed, the Crown Estate, has issued licences intended to allow developers to close off areas of the seas surface to navigation. Yet, it is the shipping interests who have been expected to justify their requirements for safe navigation. For an equitable balance between wind farms and shipping operation, it is now appropriate and not unreasonable to request that the developers justify the development areas actually needed. It is not adequate that they make reference to the development areas as ''maximum.'' Development of Wind Farms Proposals It appears that the geographical extents for licence and development were based initially on nominal capacity densities (MW/km^2) for which there is extensive data for the British Isles and Europe. Subsequently, with the increasing data now available, the developers should now be able to provide more detail of their design parameters and proposals. Unfortunately, past experience elsewhere was that developers claimed that there were too many variables under consideration. Was their reluctance to provide details until as late as possible intended to put objectors at a disadvantage? Even though the developers may not have finalised design, it is reasonable to expect that they are now able to address and resolve fundamental inputs such as turbine specific power and Irish Sea wind data. Thus, they are able to narrow down their choices and become much more specific as to the actual layout pattern and area required. For example, the documents state the minimum number (higher power) and maximum number (lower power) of wind turbines in each development, which indicates the chosen range of turbine capacities and rotor sizes. It would be misleading to suggest that there are too many variables to be more specific at this stage, as some variables cancel each other. For example, the area required for development is largely independent of rotor size (diameter). (The turbine power generated is proportional to the square of the rotor diameter. The wind turbine spacing is expressed as a multiple of rotor diameter, and thus the density of wind turbines is inversely proportional to the square of the rotor diameter. Thus to obtain the power capacity per unit area, the turbine power is multiplied by the density, and the diameters squared cancel out.) Application of Rochdale Envelope. The Rochdale Envelope (National Infrastructure Planning Advice Note 9) allows a degree of flexibility to address uncertainties. For offshore wind farms it notes (para 4.5) that these may include type and number of turbines. Para 4.12 refers to ''robust worst case scenario(s), '' which for offshore wind farms presumably includes overall geographical area for development. Notwithstanding this 'flexibility,' it now appears reasonable to request the developers to justify the actual development areas which they need. To give one specific example, what is the justification for the northern-most corner of Morgan to project apparently unnecessarily into the Douglas - Heysham shipping route?

Advice given

Dear Mr. Pennington, Thank you for your email. I apologise for the delay in reply. The proposed applications above are currently at the Pre-application stage of the Planning Act 2008 process. Further information about the process can be found in the link below to the National Infrastructure Planning website: https://infrastructure.planninginspectorate.gov.uk/application-process/the-process/ The Planning Inspectorate is unable to consider representations about the merits of any application until it has been submitted and accepted for Examination. As the applications have not yet been formally submitted to the Planning Inspectorate. Your first point of contact should be the developer and we would encourage you to contact them directly: Morgan Offshore Wind Farm Generation Assets Website for consultation: https://morecambeandmorgan.com/morgan/consultationhub/ Email: info@morganoffshorewind.com Telephone: 0800 915 2493 (Option 1) Mona Offshore Wind Farm Email: info@monaoffshorewind.com Telephone: 0800 860 6263 Morecambe Offshore Wind Farm Generation Assets Email: hello@morecambeoffshorewind.com Telephone: 01224 548642 Morgan and Morecambe Offshore Wind Farms Transmission Assets Email: info@morecambeandmorgan.com Telephone: 0800 915 2493 (Option 3) It is important that the developer is made aware of your comments at the Pre-application stage to enable them to consider the points raised before finalising their proposals and submitting the application. Should the applications be accepted for Examination you will be able to register as an Interested Party on each project by submitting a relevant representation. This must be submitted on the ‘Registration and Relevant Representation form’ which will be made available on each project webpage of the National Infrastructure Planning website at the appropriate time. Further information about registering as an Interested Party can be found in the Planning Inspectorate’s ‘Advice Note 8.2: How to register to participate in an Examination’ which can be found here: https://infrastructure.planninginspectorate.gov.uk/legislation-andadvice/advice-notes/ Shipping and navigation have been identified as aspects to be assessed in the environmental statements of all of the above projects and will be part of the evidence that each Examining Authority will consider during the Examination of each project. We will consider appropriate locations for hearings for each project once each application has been accepted for Examination. You may find it helpful to subscribe to receive email notifications for key events that occur after an application has been submitted to the Planning Inspectorate. You can do that on each project page of the National Infrastructure Planning website.