Executive Summary
The Proposed Development
1.1.1 The Proposed Development comprises the offshore elements of Berwick Bank Wind Farm which are subject of this application. The Berwick Bank Wind Farm will include both offshore and onshore infrastructure including an offshore generating station (wind turbines located in the Proposed Development array area), offshore export cables to landfall and onshore transmission cables leading to an onshore substation, with subsequent connection to the electricity transmission network.
1.1.2 Berwick Bank, as one of the largest offshore Wind Farms being proposed in the world, can substantially contribute to both the Scotland and the UK’s legally binding climate change targets by helping to decarbonise energy supply, whilst also contributing to the essential tasks of ensuring security of supply and providing low-cost energy for consumers in line with the Scotland and UK Government’s national policies.
1.1.3 Berwick Bank will also contribute materially to the economic and social landscape in Scotland and the UK as it can provide substantial employment opportunities and skills development, particularly in coastal communities, whilst also playing a major role in supporting Scotland and the UK’s supply chains.
1.1.4 The Proposed Development comprises up to 307 wind turbines to be located in the outer Firth of Forth and Firth of Tay, within the former Round 3 Firth of Forth Zone, to the south of the Seagreen 1 and 1A Offshore Wind Farm projects. The Proposed Development array area will be located within the Scottish Offshore Region, approximately 37.8 km east of the Scottish Borders coastline and 47.6 km east of the East Lothian coastline. The offshore export cables which form part of the Proposed Development will be located within both the Scottish offshore region and Scottish Territorial Waters.
1.1.5 The Applicant has secured three Grid Connection Offers from National Grid Electricity System Operator (NGESO) for 4.1GW of Transmission Entry Capacity for Berwick Bank. This includes two connections at Branxton, East Lothian and an additional connection at Blyth, Northumberland. The agreement for the third additional connection was signed in June 2022 (hereafter referred to as the “Cambois connection”). Applications for the necessary consents (including marine licences) for the Cambois connection are being applied for separately once further development work has been undertaken on this offshore export corridor.
1.1.6 An Environmental Impact Assessment (EIA) has been completed for the Proposed Development in accordance with The Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017 (as amended), the Marine Works (Environmental Impact Assessment) (Scotland) Regulations 2017 and the Marine Works (Environmental Impact Assessment) Regulations 2007 (as amended). A Habitats Regulation Appraisal (HRA) has also been completed as required under the Conservation (Natural Habitats, & c.) Regulations 1994, The Conservation of Habitats and Species Regulations 2017 and the Conservation of Offshore Marine Habitats and Species Regulations 2017 (collectively referred to as the “Habitats Regulations”)
The role of this Planning Statement
1.1.7 This Planning Statement supports the offshore applications for consent under Section 36 of the Electricity Act 1989, as well as Marine Licences under the Marine and Coastal Access Act 2009 and the Marine (Scotland) Act 2010c up to Mean High Water Spring (MHWS). A separate Onshore Planning Statement has also been prepared to support the application for planning permission under the Town and Country Planning (Scotland) Act 1997 for the Onshore Transmission Infrastructure landward of Mean Low Water Springs (MLWS).
1.1.8 The Scottish Ministers are the primary Regulatory Authority in respect of the necessary consents and licences required for the construction and operation of the Proposed Development. To allow the Scottish Ministers to properly consider the development proposals, developers are required to provide information which demonstrates compliance with the relevant legislation and policy and which allows adequate understanding of the relevant material considerations.
1.1.9 This Planning Statement demonstrates accordance with legislation and consenting requirements for the Proposed Development and sets out a clear case for consent. Importantly, Berwick Bank Wind Farm has been demonstrated to be a highly deliverable opportunity because of its proposed location, extent of previous surveys and studies and selected technology. When delivered, it will make a significant and important contribution to decarbonisation, security of supply and affordability, in the very near future. The Proposed Development is wholly consistent with the Scottish Energy Strategy and UK energy policy and is critical if Scottish and UK policy aims and legislative Net Zero targets are to be achieved within targeted timescales.
Why Consent Berwick Bank?
1.1.10 The Application for Berwick Bank Wind Farm presents an opportunity to deliver 4.1GW of offshore wind energy, with significant generation operational to the grid by 2030. Extensive work has been undertaken by the Applicant to identify opportunities for maximising generating capacity that can be delivered by the Project (4.1 GW) whilst reducing and mitigating potential adverse effects on the environment through design changes and reductions in the boundary of the Proposed Development array area.
1.1.11 The Statement of Need for Berwick Bank demonstrates that the deployment of offshore wind, and specifically the Berwick Bank Project is needed to make a significant contribution to the UK Government’s following national policy aims of decarbonisation:
> Net-zero and the importance of deploying zero-carbon generation assets at scale;
> Security of supply (geographically and technologically diverse supplies); and
> Affordability of energy.
1.1.12 Maximising the generating capacity of the Proposed Development array area will enable the Project to make significant strides towards the achievement of Scotland’s legally binding Net Zero commitment by 2045 and the UK’s target by 2050 as well as significant contribution towards achieving Scottish interim targets of reducing emissions by 75% by 2030. Moreover, it will make an essential contribution to the delivery of targets of 11 GW of offshore wind capacity in Scotland and 50 GW in the UK of offshore wind generation by 2030. Most importantly, by utilising proven technology (fixed foundations) this significant contribution can be delivered quickly (with significant generation by 2030) and competitively by a highly experienced and reputable developer.
1.1.13 Without Berwick Bank, it is very possible that delivery of multiple policies will fall short, including those as set out in: the Scotland Sectoral Marine Plan, Scottish Energy Strategy, The Ten Point Plan, UK Net Zero Strategy and UK Offshore Wind Sector Deal, as well as the targets set by the Climate Change (Scotland) Act 2009, The Climate Change (Emissions Reduction Targets) (Scotland) Act 2019, the (UK) Climate Change Act 2008 (as amended) and the Net Zero Strategy: Build Back Greener. Offshore wind is recognised as being an important technology for low-carbon generation and the urgent need for large capacities of low-carbon generation is clear to avoid compromising security of electricity supply. Specifically, Berwick Bank will be a necessary part of the future generation mix, and as such will make a valuable contribution in the direction of adopted Scotland and UK Government policy and achievement of decarbonisation commitments.
1.1.14 Having initially considered developing the Proposed Development as two separate projects (Marr Bank and the 2020 Berwick Bank) it became apparent that delivery of the full 4.1 GW capacity by the early 2030s could only be achieved through the development of one single larger project, the Berwick Bank Wind Farm.
1.1.15 Although the two projects were combined to create one larger single project, subsequent changes made to the Berwick Bank Wind Farm Project boundary have resulted in the Proposed Development array area being only 30.8% larger than the 2020 Berwick Bank project (1,010.2 km2 compared to 775 km2), whereas the maximum generating capacity of the Proposed Development array area has increased by 78.3% (4.1 GW compared to 2.3 GW). The maximum number of turbines required to generate 4.1 GW has also only increased by 26.9% (307 compared to 242) as a result of using larger wind turbines.
1.1.16 The Berwick Bank Wind Farm occupies the only remaining fixed bottom wind farm site in Scotland with capacity to deliver 4.1 GW of capacity. It is therefore important to note that if the Berwick Bank Wind Farm is not consented or unable to deliver the maximum achievable generating capacity, there are no alternative opportunities either within the Firth of Forth zone or elsewhere in Scottish Waters for the same capacity to be delivered against a similar time frame (early 2030s). All developable seabed is required to make continued progress in the fight against climate change.
1.1.17 Berwick Bank also offers an important opportunity to expedite energy security – a critically important national policy objective at this time. If developed to its full technically achievable capacity, Berwick Bank would provide enough energy to replace a proportion of imports to the UK.
1.1.18 Reducing the UK dependency on hydrocarbons is essential and consenting the full technical potential at Berwick Bank by the early 2030s would make a substantive step forward in that objective.
1.1.19 Another important consideration is the cost efficiency of delivering the scale of offshore wind proposed at Berwick Bank. The proposed location is assessed as being a lower-cost location than other alternative sites identified for delivery should Berwick Bank not be consented. The delivery of alternative, less progressed sites is likely to cost significantly more and take much longer to realise. The reasons for this include:
> The seabed at Berwick Bank is shallower than the seabed lease areas in other locations and the proposed location is relatively close to shore. This allows lower cost technical solutions to be utilised compared to longer time frames for technological delivery for deeper seabed solutions.
> The seabed and marine environment at Berwick Bank is well surveyed. This provides increased confidence in the ability of the lease area to accommodate target capacities for generation. This improves the understanding of the levels of environmental impact and reduces uncertainty in assessments. Confidence in the overall ability to deliver the technical capacity is higher than those locations which do not benefit from the same level of survey.
> Wind Farm construction is already ongoing in the Firth of Forth, with Seagreen 1 located close by and on similar sub-sea terrain. Berwick Bank will be able to benefit from construction experience there and improve efficiency and help to underpin accurate connection dates and cost estimates.
> The points of connection identified for Berwick Bank are likely to attract lower onshore transmission costs and losses for the project than for comparable capacity connected further North. In turn, this will deliver low carbon energy to consumers at a lower overall cost than any other reasonable alternatives, including ScotWind.
1.1.20 The Proposed Development benefits further from confidence in delivery in using tried and tested fixed bottom technology (compared to new floating technology) and through delivery by a developer with a proven track record of delivering offshore wind in Scottish waters and in the specific area of the project.
The ScotWind Context
1.1.21 The delivery of the full potential capacity in one development enables efficiencies in delivery and consenting. As noted above, Berwick Bank Wind Farm is the largest developable fixed foundation site in Scotland. Of the 18 option areas awarded in January 2022 under the Crown Estate Scotland’s ScotWind Offshore Wind Leasing Round, six option areas are for fixed foundation projects. The largest of these, the BP E1 option area is approximately 3GW[1] with a further three option areas indicating fixed wind capacity of up to 2GW each[2]. As of November 2022, Scoping Reports have been submitted for two of these 2GW projects (OceanWinds Caledonia Offshore Wind Farm2 and Offshore Wind Power Limited’s West of Orkney Offshore Wind Farm).
1.1.22 Of the six fixed foundation projects, two have pre-2030 grid connections[3] (2GW for Scottish Power Renewables (SPR) in 2028 and 750 MW for Offshore Wind Power Limited (OWPL) in 2029[4]). Both SPR and OWPL also have additional grid connection in 2031. The majority of other ScotWind projects either have 2033 grid connection, or do not yet have a grid connection agreement.
1.1.23 Based on this, it can be concluded that there are currently no other projects in the Scottish pipeline which could deliver the equivalent capacity in the timeframes in which Berwick Bank can deliver. All other ScotWind projects are scheduled for delivery post 2030. Delaying the consenting of the full available development capacity, which has been surveyed and assessed as capable of accommodating and delivering renewable energy generation would have a ratcheting-up effect on the capacity of offshore wind required to be developed under 2022 ScotWind and subsequent seabed leases in order to hit Net Zero. This is because taking actions later allows time for carbon emissions to accumulate further and global warming to progress yet further before the next round of sites are delivered. This would then require an increased magnitude of subsequent actions required to deliver decarbonisation.
1.1.24 In summary on Scotwind, it is essential for Scotland that Berwick Bank is developed, and developed at its full 4.1GW of potential capacity for the following reasons.
> Against current development timeframes, which include grid connection, the great majority of ScotWind sites will not commission before 2030.
> SSE is a reputable and highly experienced developer with a proven track record in successfully developing and delivering offshore wind projects (from inception to operation).
> Berwick Bank uses a mature fixed bottom technology in a marine environment and water depth where offshore wind delivery is tried and tested.
> Berwick Bank is the next step to larger offshore projects in Scotland and to the delivery of ScotWind.
> The bringing forwards of ScotWind connection dates requires the bringing forward of onshore transmission system works to support power flows. The same does not apply to Berwick Bank.
> Berwick Bank therefore remains advantageous versus ScotWind in relation to grid connection dates and confidence of delivery and therefore in terms of its contribution to decarbonisation for Scotland and the UK and importantly can significantly contribute to the critical 2030 emission reduction targets.
Policy Appraisal
1.1.25 The Proposed Development has been appraised against the relevant energy and planning policy framework. In addition to the energy policy considerations referenced above, the policy appraisal set outs that although some significant environmental impacts are identified, these need to be viewed in the context of the design and siting approach taken for the Project and in relation to proposed mitigation. It is considered that the adverse effects that do arise, are outweighed by the benefits that would result.
1.1.26 Alternatives have been carefully considered and ruled out for robust reasoning. The Proposed Development has been carefully formulated and focused down to appropriate scale parameters by way of boundary revisions to minimise environmental effects.
1.1.29 Given that conclusions of AEOI have been reached under both the Scoping Approach and Developer Approach, it is deemed necessary for the Applicant to provide the requisite information and justification (the Derogation Case) to satisfy the HRA Derogation Provisions under the Habitats Regulations in respect of the species for the SPAs identified. Under the Derogation Provisions decision-makers may grant consent for a plan or project where it is demonstrated that the plan or project must be carried out for imperative reasons of overriding public interest (IROPI), there are no alternative solutions and that compensatory measures can be secured to ensure that the overall coherence of the national site network is maintained. It is for the Scottish Ministers in conjunction with the Secretary of State to determine whether the substantial, long-term public interests that Berwick Bank serves, outweigh the public interest in the conservation of the qualifying species of the affected SPAs.
1.1.30 The assessment set out by the Applicant, in terms of the balance to be struck, is that there is an imperative overriding public interest in authorising Berwick Bank to further the fundamental policy objectives it will serve, which it is considered demonstrably outweighs the AEOI which is predicted in respect of the identified SPAs.
1.1.31 Moreover, the Derogation Case shows that predicted impacts are more than compensated for, by way an already well progressed and viable programme of compensation measures, giving more than enough confidence to consent the full application, and also presenting a detailed and carefully considered model of strategic compensation that can be used by the Scottish Government much more widely than only in relation to Berwick Bank. Such an approach to ensure appropriate steps are taken would enable not just Berwick Bank, but the wider programme of Scotwind projects to go ahead with more than adequate compensation for any potential ecological effects.
Conclusions & the Planning Balance
1.1.32 A planning appraisal inevitably involves the striking of a balance between likely adverse effects, the extent to which they can be adequately mitigated and consideration of project benefits. Alongside the effects of the Project identified through the EIA process and reported in the EIA Report, key benefits will include:
> With the potential capacity to generate an estimated 4.1 GW, Berwick Bank is the largest offshore wind farm currently in development and, once built will be one of the largest offshore wind farms in the world. The Project will be a substantial infrastructure asset, capable of making a significant single near term contribution to decarbonisation objectives by delivering substantial amounts of low-carbon electricity – enough to power in excess of 5 million homes[5] each year, from as early as 2026.
> Berwick Bank is essential to close the ‘gap’ on the Scottish Government’s offshore wind deployment target of 11GW by 2030;
> Berwick Bank will contribute significantly to meeting climate change emission reduction targets in the 2020s and into the early 2030s. The 2030 global emissions reduction ambition ‘gap’ will be closed only by bringing forward such projects which connect as much capacity as possible to as early as possible. Over its lifecycle the electricity generated by the Project will save 9,178,312 tCO2e from being emitted into the atmosphere that would otherwise have been emitted from conventional, higher carbon emitting forms of energy generation (i.e. fossil fuels). When construction phase greenhouse gas emissions are included, the Project will save 2,951,519 tCO2e from being emitted into the atmosphere over its lifecycle.
> Berwick Bank will contribute significantly to grid stability and security of supply. The British Energy Security Strategy (April 2022) aims for 50GW of offshore wind deployment by 2030.
> Berwick Bank will also contribute materially to the economic and social landscape in Scotland and the UK and can provide substantial employment opportunities and skills development, particularly in coastal communities, whilst also playing a major role in supporting Scotland and the UK’s supply chains for offshore wind;
> Economic benefits through the creation of jobs, work-force upskilling and investment in supply chain are also expected from the construction, operation and maintenance of Berwick Bank. Such benefits live on beyond the immediate construction of the project and can provide a long-lasting legacy (e.g. skilled workers who go on to work on successive OWF projects in the years and decades to come). Key economic benefits include:
- The Project could potentially add up to an estimated £8.3 billion to the UK economy as a whole over its life-time.
- During development, manufacturing, construction, and installation activities for Berwick Bank, the potential increase in employment across Scotland is estimated to be 6,000 total Full Time Employment (FTE) years (direct employment).
- In annual terms, the construction phase of Berwick Bank could support approximately 4,800 FTE job years across Scotland.
- Once operational, Berwick Bank would support around 750 jobs per annum and 26,100 total (FTE years) in Scotland (direct, indirect and induced).
- In terms of investment, during manufacturing, construction, and installation activities, the Proposed Development has the potential to generate £360 million GVA per annum and £450 million in total over the whole construction period at the Scotland national level. This is equivalent to 80% of the 2019 offshore wind sector GVA in Scotland.
> Berwick Bank is compatible with Scottish planning and energy policies and would substantially help attain policy objectives, serving the public interest;
> Maximising the capacity of generation in the resource-rich, accessible and technically deliverable Berwick Bank area, is to the benefit of all GB consumers, and the wind industry generally.
1.1.33 It is considered that the overall policy appraisal presented in this Planning Statement demonstrates a compelling case that Berwick Bank would deliver significant benefits in the wider public interest. The Project has been designed and assessed in full accordance with relevant legislative requirements and the underlying aims and objectives of the policy framework.
1.1.34 Overall, Berwick Bank can substantially contribute to both the Scotland and the UK’s legally binding climate change targets by helping to decarbonise energy supply, whilst also contributing to the essential tasks of ensuring security of supply and providing low-cost energy for consumers in line with the Scotland and UK Government’s national policies.
1.1.35 Berwick Bank will also contribute materially to the economic and social landscape in Scotland and the UK as it can provide substantial employment opportunities and skills development, particularly in coastal communities, whilst also playing a major role in supporting Scotland and the UK’s supply chains.
1.1.36 It must follow from the above that the benefits that would arise from the Project should be afforded substantial weight in the planning balance. The delivery of this renewable generating infrastructure will substantially assist in the delivery of the Net Zero policy imperative, by the critically important date of 2030.
1.1.37 Consideration of the application will involve striking a balance between the need for the Project, its benefits and the mitigation of (and compensation above and beyond) predicted environmental effects. It is considered that the substantial, clear and compelling benefits of the Proposed Development outweigh any potential individual or cumulative adverse effects.
1.1.38 For all the above reasons the Section 36 consent and Marine Licence applications should be granted.
1. Introduction
1.1 Background
1.1.1 This Planning Statement has been prepared on behalf of Berwick Bank Wind Farm Limited (BBWFL), a wholly owned subsidiary of SSE Renewables (SSER) hereafter referred to as ‘the Applicant’. The Applicant is developing the Berwick Bank Wind Farm and associated offshore and onshore infrastructure (‘the Project’). The Planning Statement is submitted in support of the applications for consent for the offshore elements submitted under Section 36 of the Electricity Act 1989 (as amended) and the applications for Marine Licences under the Marine and Coastal Access Act 2009 and the Marine (Scotland) Act 2010 for the Proposed Development (as described in the EIA report and accompanying application documents).
1.1.2 The Proposed Development is an offshore wind farm located in the outer Firth of Forth and Firth of Tay, approximately 37.8 km east of the Scottish Borders coastline (St. Abb’s Head) and 44.8 km to the East Lothian coastline. The Project comprises both offshore and onshore infrastructure required to generate and transmit electricity from the Proposed Development array area to a Scottish Power Energy Networks (SPEN) 400 kV Grid Substation located at Branxton, southwest of Torness Power Station. The export cables will make landfall on the East Lothian coast at Skateraw.
1.1.3 The Applicant is also developing an additional export cable and grid connection to Blyth, Northumberland (hereafter the “Cambois connection”). Applications for the necessary consents (including marine licences) will be applied for separately once further development work has been undertaken on this offshore export corridor. The Cambois connection has been included as a cumulative project for the purposes of the offshore EIA and assessed based on the information presented in the Cambois connection Scoping Report submitted in October 2022 (SSER, 2022e). An EIA will be prepared to support any relevant consent applications that are required to deliver the Cambois connection which will also consider cumulative effects with the Proposed Development.
1.1.4 SSER is a leading developer, owner and operator of renewable energy across the UK and Ireland. This includes an impressive portfolio of offshore wind projects in the UK including the world’s largest offshore wind energy project, the 3.5 GW Dogger Bank Wind Farm in the North Sea, which is a joint venture with Equinor and Eni, as well as Scotland’s largest and the world’s deepest fixed bottom offshore site, the 1.1 GW Seagreen Offshore Wind Farm in the Firth of Forth, a joint venture with Total Energies. In addition to this SSE are developing the Ossian ScotWind project and North Falls (Round 3 extension project). The background to the acquisition of the relevant Development Agreement with the Crown Estate for the development area is set out in detail in the EIA Report Volume 1, Chapter 4 Site Selection and Alternatives.
1.1.5 An Environmental Impact Assessment (EIA) has been undertaken and an EIA Report has been submitted in support of the Proposed Development in accordance with the Electricity Works (Environmental Impact Assessment) (Scotland) Regulatio0ns 2017 (as amended) and The Marine Works (Environmental Impact Assessment) Regulations 2017 (as amended). A separate Onshore EIA Report and Planning Statement have been prepared pertaining to the onshore elements of the Project which will be consented under the Town and Country Planning (Scotland) Act 1997 (as amended).
1.1.6 A HRA has also been completed as required under the Conservation (Natural Habitats, & c.) Regulations 19994, the Conservation of Habitats and Species Regulations 2017 and the Conservation of Offshore Marine Habitats and Species Regulations 2017 (collectively referred to as the “Habitats Regulations”).
1.1.7 This Planning Statement provides and assessment of the Proposed Development against the relevant marine planning and renewable energy policy framework and relevant provisions of the National Planning Framework 3 (NPF3), emerging NPF4, and the Local Development Plan, in so far as the latter is relevant to offshore effects. The Statement is supplementary to, and separate from the EIA Report, and both documents should be read in conjunction.