Focus on floating offshore wind
Legal
by
Paul Maile and Karen Mutton
I n November 2020 the government announced its Ten Point Plan for a Green Industrial Revolution. Aggressive expansion of offshore wind was top of the list. Challenging targets were set for 40GW of offshore wind to be generated by 2030, with 1GW to come from floating turbines.
Fast forward 18 months to April 2022 and, catalysed by the war in Ukraine and the cost-of-living crisis, the British Energy Security Strategy increased those targets to 50GW and 5GW respectively. That is a 400% increase in expectations for floating wind, and is somewhat surprising given that the UK will largely be starting from scratch. At present there is circa 80MW of floating wind capacity in UK waters, mostly split between the Hywind and Kincardine projects in Scotland. The latter, at 50MW and just five turbines, is the largest such project operational in the world.
Large-scale deployment of floating wind required to hit the target will therefore require a significant ramping up of the industry, and for the UK to be the pioneer of deploying it. It is worth, then, exploring how that is going to happen.
In November 2020 the government announced its Ten Point Plan for a Green Industrial Revolution. Aggressive expansion of offshore wind was top of the list. Challenging targets were set for 40GW of offshore wind to be generated by 2030, with 1GW to come from floating turbines.
Fast forward 18 months to April 2022 and, catalysed by the war in Ukraine and the cost-of-living crisis, the British Energy Security Strategy increased those targets to 50GW and 5GW respectively. That is a 400% increase in expectations for floating wind, and is somewhat surprising given that the UK will largely be starting from scratch. At present there is circa 80MW of floating wind capacity in UK waters, mostly split between the Hywind and Kincardine projects in Scotland. The latter, at 50MW and just five turbines, is the largest such project operational in the world.
Large-scale deployment of floating wind required to hit the target will therefore require a significant ramping up of the industry, and for the UK to be the pioneer of deploying it. It is worth, then, exploring how that is going to happen.
Floating wind potential
To date, rights for more than 15GW of floating wind projects have been awarded under the Scotwind leasing round, and a further 4GW has been identified for delivery in the Celtic Sea by 2035.
The first step in the delivery process is securing planning consents, and support for the escalation is emphasised in the updated draft national policy statements for energy issued March 2023. All offshore wind in England and Wales will be considered a “critical national priority”, meaning that, in all but the most exceptional cases, the urgent need to deliver will outweigh environmental impacts. Scotland’s Offshore Wind Policy Statement already acknowledged Holyrood’s declared climate emergency and a statutory commitment to reach net zero by 2045, with offshore wind generation playing a vital part in meeting the challenge.
This represents a huge opportunity for the energy industry, in terms of potential scale of deployment and contribution to clean energy generation, but also in terms of supply chain opportunities and investment in critical infrastructure, for the benefit of the UK economy as a whole.
The distinction between fixed and floating infrastructure
The main advantage of floating turbines is that they can be deployed in areas not economically and technically accessible to fixed-bottom turbines, which are most suited to relatively shallow waters, and construction-friendly seabed conditions.
Floating wind turbines tend to use anchors to secure the floating elements via moorings, so can be located further offshore in deeper waters. This opens up areas of higher consistent wind speeds which, in simple terms, means more power.
Floating turbine design is not uniform and, it goes without saying, they must be suitable for their location and weather conditions. Turbines installed further offshore must be capable of withstanding the more extreme weather in these locations, noting that the larger the buoyant element of the structure above the sea level, the more susceptible it will be to wave action.
Floating wind generally uses one of three different types of mooring lines – tension, taut or catenary – with associated seabed anchors. Where tension or taut lines are used, they may require more intrusive anchoring techniques, so that the moorings are strong enough to keep the turbine stable. Catenary moorings may use less-intrusive anchors, but have longer mooring lines that allow the floating structure to drift in high waves, which may drag on the seabed, resulting in scour and associated adverse impacts for benthic and other marine ecology throughout the operational life of the project. Suspended intra-array cables may have similar effects. However, this infrastructure generally reduces environmental impacts on the seabed compared with fixed-bottom projects, for which foundations are frequently piled with trenched or buried array cables.
Deployment of fixed-bottom offshore wind farms around the UK has allowed the collation of a large and detailed evidence base in terms of their impact on the environment which can be drawn on for new projects, but there will be novel issues for consideration, including:
ν the impact of turbines further offshore may have different collision risks for birds compared to those presented in locations where fixed-foundation turbines have been located;
ν potential risks presented to marine mammals from entanglement with mooring lines or suspended inter-array cables are not encountered with fixed-bottom projects;
ν the nature of floating infrastructure and suspended cables may mean that the scope for co-existence with shipping interests and commercial fisheries is reduced. This may, however, have an associated conservation benefit if the seabed and fish stocks can recover during the operational lifetime of the project.
Evidence generated by the operation of the Hywind and Kincardine wind farms, and emerging demonstrator projects, will help address these points.
Commonalities
Our experience has shown that the consenting risks for offshore floating wind are similar to those for fixed-foundation wind projects, including identification of the appropriate consenting regime, the need to carry out an environmental impact assessment, and input to a habitats regulations assessment where the project has the potential to impact on protected habitats or species. The time taken to secure a consent is a key issue for both types of projects.
Different consenting regimes operate in Scotland, England and Wales, and there is a potential for multiple consents to be required for one project – although some can be secured through a single process, such as a deemed planning permission being granted in connection with a consent under the Electricity Act 1989, or a multi-faceted award through a development consent order. This system will not be simplified for deployment of floating wind projects.
Considerations relating to export cable location and installation, whether to a project specific landfall location or proposed to connect into the holistic network design solution being progressed by National Grid, are also common to both fixed and floating wind farms. Issues arise for both technologies associated with the costs and risks presented by lengthy export cable connections – which may be more acute for floating schemes located further offshore – as well as rights to connect and timing of capacity availability.
Other opportunities and constraints
The push to deliver more floating wind capacity also recognises the wider benefits that will accrue to the UK economy. The Floating Offshore Wind Demonstration Programme is providing funding to projects for development of technology to overcome particular challenges to increased deployment. The recently issued guidance for the Floating Offshore Wind Manufacturing Investment Scheme also recognises the need for investment to facilitate capacity and capability, and to deploy and service the scale of the floating offshore wind pipeline. In particular, it identifies the need for port facilities, combining a substantial depth of water with heavy-lift capacity and extensive quayside space to accommodate assembly of floating turbines and their associated infrastructure before transport to project locations.
There are currently no ports in the UK which fulfil the projected infrastructure requirements and a recent Floating Wind Industry Roadmap by RenewableUK identifies a critical need for UK ports to be developed to provide manufacturing, assembly, integration, operation and maintenance capacity. Co-ordinated delivery of these facilities across a number of ports will require a strategic approach, and commercial agreement between currently competing operations, which will take time to settle.
There is also a need for a significant increase in the workforce and new skills, with scope for up to 45,000 jobs in the industry by 2040. £160m in grant funding is to be made available to support these initiatives and deliver on the Ten Point Plan.
While the focus for increased offshore floating wind capacity has to date centred on provision of energy directly to the grid, the technology has the potential for much wider application. The Hywind Tampen floating offshore wind project in Norway is already supplying electricity to oil and gas platforms in the North Sea, and there is scope for establishing large-scale floating wind farms that can be used for the generation of green hydrogen. Piped to shore, potentially in converted natural gas pipes, this could be used as a transport or other combustion fuel source – and provide another key contribution to the green industrial revolution.
It is clear that the 2030 targets represent a big ask, but there is a willingness in the industry, government and the supply chain to take on the challenge.
Paul Maile is head of planning and infrastructure consenting and Karen Mutton is legal director at Eversheds Sutherland
Image © Hugo Amaral/SOPA Images/Shutterstock