Representation by Judith Ann Clementson
- Date submitted
- 12 February 2020
- Submitted by
- Members of the public/businesses
I am opposing the Aquind Limited's application for a DCO based the following reasons: - UK Statistical Information relating to energy consumption since 2000 - Climate Emergency and Strategic Planning to Reduce Carbon Impact - Affects of the Brexit Decision on Aquind and other Interconnector Projects - Cap and Floor regime and ‘Exempt Routes’ - Local considerations: impact to residents, local businesses, environment and ecology, including long term mitigation for road and landscape maintenance - Long term mitigation for decommissioning and making good Considerable statistical information from the ONS, OFGEM and other reputable organisatiions suggests that our UK renewable energy production has increased whilst our UK energy produced using fossil fuels has reduced. Approximately 10% of imported energy is electricity (oil and gas is the main import). However, our overall consumption has fallen from 357 TWh in 2005 to 307 TWh in 2018 and is expected to fall by a further 3.7% between 2018 and 2023. A 'climate emergency' has been declared in the UK and most other Nations and new legislation has ensured 'smart' use of energy resources which are already making a considerable difference to the overall energy consumption, ie green buildings, EVs and Hybrid transport. We are also increasing our own production of green fuel as our fossil fuel production facilities close. If we have an over supply of energy available through interconnectors and it is not required, the 'cap and floor' guarantee may see the UK consumer ultimately paying a 'top up' to the interconnector provider to enable the guaranteed revenue 'floor' level to be maintained. Brexit has increased uncertainty about the future relationship and tariffs that may be imposed if the UK does not remain in the IEM which requires adherance to other EU legislation such as the single market, FOM and EJC jurisdiction. Aquind Limited applied for an 'exemption'under Article 17(1) of Regulation (EC) No 714/2009. OFGEM and France's Commission de Regulation de L’energie (CRE) could not agree and it was passed to the Agency for the Co-operation of Energy Regulators (ACER) for a decision. They agreed with the CRE and it was refused. Aquind Limited had indicated "without an exemption, the Aquind interconnector cannot progress through construction and to commercial operation’ because ‘a regulated regime with financial underpinning is not available to Aquind in France". I am therefore concerned that the project may commence, the costs escalate (as have those for HS2) and Aquind will be unable to complete the project through lack of funding. I am also concerned that the UK will not remain in the IEM and no agreement to allow zero tariff cross-border energy is reached. There are many local aspects of concern to the residents of Portsmouth, Waterlooville, Denmead and surrounding areas which relate to the construction of the Interconnector which will cause major disruption for at minimum of 2 years to traffic flow; cause businesses along the route to suffer and a negative impact on an already struggling retail section in Waterlooville and Portsmouth. I understand the Aquind's preference for the highway route as this enables them to deal with local authorities only and negates the need to deal with many landowners which would be the case if they routed the interconnector across greenfield sites. No provision is being made in Aquind's submission for on-going maintenance of the roads which are likely to suffer from damage caused by the heat from the cables drying out the clay soil under the roads. In addition, there appears to be no plan or provision made for the decomission of the Converter Station once this interconnector is not longer viable.