5.6 Other Considerations & Derogation Case
5.6.1 As set out in Section 2.5 above, the Berwick Bank Wind Farm - Report to Inform Appropriate Assessment (RIAA) prepared as part of the consent application concludes that there is a risk that the Proposed Development would have an adverse effect on the integrity (AEOI) of the following SPAs either from the Proposed Development in isolation or in-combination with other projects:
> The Forth Islands SPA;
> Fowlsheugh SPA;
> St Abb’s Head to Fast Castle SPA;
> Farne Islands SPA;
> East Caithness Cliffs SPA;
> Troup, Pennan & Lions Head SPA;
> Buchan Ness to Collieston Coast SPA;
> Flamborough and Filey Coast SPA.
5.6.2 The species at these sites for which adverse effects have been identified include kittiwake (collision risk), guillemot, razorbill and puffin (displacement).
5.6.3 In accordance with the relevant provisions of the Habitats Regulations, the Applicant has (see the Derogation Case Report) demonstrated that:
> there are no alternative solutions to Berwick Bank;
> There are “imperative reasons of overriding public interest” (IROPI) for the project to proceed; and
> Any necessary compensatory measures can be secured to ensure that the overall coherence of the national site network is protected.
5.6.4 Together these provisions are referred to as the “HRA Derogation Provisions”.
5.6.5 The Applicant accepts that the application of the HRA Derogation Provisions is necessary, because of a risk of AEOI of the SPAs listed; and has therefore provided the information necessary to support a clear and overriding HRA Derogation Case for Berwick Bank, which could be relied upon by the Scottish Ministers if required.
5.6.6 The Applicant is confident that the public interest in Berwick Bank overrides any potential harm to each of the above SPAs (and cumulatively) for the reasons set out in the HRA Derogation Case, which in summary include:
> Berwick Bank will contribute significantly to meeting climate change reduction targets in the 2020s and into the early 2030s.
> 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 grid stability and security of supply;
> Berwick Bank is capable of making a substantial contribution to the Scottish economy;
> Berwick Bank will bring forward an important near-term opportunity for supply chain investment in Scotland; and
> Berwick Bank is compatible with Scottish planning and energy policies, serving the public interest.
5.6.7 The Derogation Case concludes that the long-term public interest that Berwick Bank delivers demonstrably outweighs the potential harm to each of the European sites (and cumulatively). Moreover any harm that does result will be compensated for via a developed, deliverable programme of compensation measures. There are no alternatives to Berwick Bank. As the project is a fundamental component of both Scotland and the UK’s need and obligations to address climate change, the potential harm is considered to be clearly outweighed by the clear public interest.
5.7 Conclusions
5.7.1 From consideration of all of the factors discussed and presented above, residual significant environmental effects are considered to be very limited. When considered in the context of the relevant policy and legislative considerations, it is considered that the Proposed Development meets the relevant policy requirements which are aimed at, increasing renewable energy capacity, whilst minimising effects on human health, minimising wider environmental harm and ensuring that conflicts with other users of the marine environment are kept to a minimum.
6. Benefits of the Proposed Development
6.1 Introduction
6.1.1 This Chapter describes the benefits of the Proposed Development, the key elements of which relate to the generation of renewable electricity, climate change and socio-economics. The conclusions of this Chapter make reference to support which can be drawn in this regard from relevant climate change and renewable energy policy objectives as set out in Chapter 3.
6.2 Renewable Generation, Emission Savings & Security of Supply
Renewable Generation
6.2.1 As explained, the Project will involve a maximum of 307 wind turbines to be installed in the Proposed Development array area. The Proposed Development has secured Grid Connection Offers from National Grid Electricity System Operator (NGESO) for 4.1GW of Transmission Entry Capacity. 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;
6.2.2 The Project proposes a substantial infrastructure asset, capable of delivering large amounts of low-carbon electricity – enough to power in excess of 5 million homes[11] each year, from as early as 2026. This is in line with the CCC’s recent identification of the need for urgent action to increase the pace of decarbonisation in the GB electricity sector;
Decarbonisation
6.2.3 A Climate Assessment Report has been prepared for the Proposed Development (Appendix 21 within the EIA Report). The report assesses the effects of the Project on climate through GHG emissions, and also examines the vulnerability and resilience of the Project to climate change.
6.2.4 As set out in Chapter 3 of this Planning Statement, the UK Government is legally bound to achieve net zero carbon emissions by 2050 and the Scottish Government has a statutory target to achieve this by 2045. ‘Net zero’ means that the total GHG emissions produced would be equal to or less than the amount removed from the atmosphere, through a combination of GHG emission reduction and removal. The UK Government has introduced a series of carbon ‘budgets’ for five-year periods, which act as stepping-stones to achieve the overall reduction in GHG emissions by 2050. The five-year budgets are currently set up to 2037 and the UK is ‘off track’ with later budgets within this range.
6.2.5 The assessment estimates that the Project will produce approximately 505,589,525 MWh of low carbon electricity during its 35-year operation and maintenance phase. Over its lifecycle the Project will produce an emission intensity of 15 gCO2e/kWh. The electricity generated by the Project will save approximately 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 GHG emissions are included (6,226,793 tCO2e), the Project will save 2,951,519 tCO2e from being emitted into the atmosphere over its lifecycle.
6.2.6 The assessment explains that it will take the Project 8 years and 2 months to ‘pay back’ the GHG emissions relating to the construction phase from the start of operation. This ‘payback’ period is in line with both the UK and Scottish Governments’ net zero ambitions as the carbon savings will start in 2036. Due to the carbon savings that the operation and maintenance phase will produce from low carbon electricity generation, the Project is assessed in the EIA Report as having a significant beneficial effect on the climate.
6.2.7 It should also be noted that the projected carbon savings are likely to be greater than estimated in the assessment as it uses a publicly available load factor from RenewableUK, which is based on performance of existing offshore wind turbines; however this load factor is expected to increase in the future due to the inclusion of actual site wind data measurements, and improvements in wind turbine technology and associated operation and maintenance activities that are included in the load factor.
6.2.8 In addition, the implementation of the Cambois connection, which is related to the Project but will be consented separately, will be dependent on the completion of the Project. Therefore, the estimated GHG emissions resulting from the Cambois connection have been assessed cumulatively with the GHG emissions from the Project. The Cambois connection will be constructed during a two-year period between 2028 and 2031.
6.2.9 The Project’s significant beneficial effect in relation to climate during the operation and maintenance phase is not changed with the implementation of the Cambois connection, nor is the overall significant beneficial effect of the Project on the climate during its lifetime.
Grid Balancing Benefits & Security of Supply
6.2.10 Berwick Bank’s connection to the National Electricity Transmission System (NETS) means that it will be required to play its part in helping National Grid Electricity System Operator (ESO) manage the national electricity system. This includes participating in mandatory balancing markets (to help balance supply and demand on a minute-by-minute basis and provide essential ancillary services) as well as providing visibility to the GB power market of its expected generation. This means that the low marginal cost wind power it will produce, can be forecast and priced into future contracts for power delivery by all participants, thus allowing all consumers to benefit from the market-price reducing effect of low-marginal cost offshore wind generation.
6.2.11 Reducing Scotland and the wider UK’s dependency on hydrocarbons has important security of supply, electricity cost and fuel poverty avoidance benefits. Those actions already urgently required in the fight against climate change are now required more urgently for global political stability and insulation against dependencies on rogue nation states.
6.2.12 By maximising the capacity installed at Berwick Bank, the Project delivers the greatest possible hydrocarbon usage reductions, and the greatest possible opportunity to reduce dependency on foreign imports, as demonstrated in the Statement of Need. This sets out that if developed at its full technically achievable capacity, Berwick Bank would provide enough energy to replace 19% of Russian gas imports to the UK. This demonstrates the significant national benefit to energy security provided by a fully developed Berwick Bank scheme.
6.2.13 Berwick Bank is highly likely to cost less to the end consumer than the cost of developing OWF capacity elsewhere in Scotland, due to the optimum environmental conditions (shallow, close to shore), technology (fixed turbines), high confidence in capacity owing to extensive survey of the site, efficient construction due to the nearby Seagreen OWF construction, which is ongoing, and lastly, low transmission costs due to onshore connection points.
Conclusions
6.2.14 The Statement of Need for Berwick Bank is a key supporting document. It demonstrates that the deployment of offshore wind, and specifically Berwick Bank is needed to make a significant contribution to the following UK Government’s national policy aims in relation to decarbonisation. It should be referred to for its detail – in relation to:
> Net-zero and the importance of deploying zero-carbon generation assets at scale, such as with the Project;
> The significant carbon savings that would result;
> Security of supply (geographically and technologically diverse supplies); and
> Benefits in relation to affordability of energy.
6.2.15 As concluded in the Statement of Need, Berwick Bank can make a single, large, meaningful and timely contribution to decarbonisation and security of supply, while helping lower bills for consumers throughout its operational life, thereby addressing all important aspects of Scotland and the UK’s legal obligations and existing and emerging Government policy.
6.3 Socio-Economic Considerations
6.3.1 The socio-economic impact (SIA) of the Proposed Development is set out in Chapter 18 of the EIA Report (Volume 2), which refers to an economic impact study carried out by independent renewable energy consultants, BVG Associates (BVGA). A summary of the key findings are set out below.
6.3.2 The study considers various scenarios and shows that the Berwick Bank Wind Farm Project could add potentially up to an estimated £8.3 billion (offshore and onshore) to the UK economy as a whole over the life-time of the Project.
6.3.3 Berwick Bank Wind Farm Project is therefore capable of providing substantial socio-economic benefits to the Scottish economy, including facilitating confidence in the Scotland supply chain, growing a skilled workforce, improving Gross Value Added (GVA) and providing wider community benefits.
Employment
6.3.4 During manufacturing, construction, and installation activities, the assessment estimates that the Proposed Development would support around 4,800 jobs per annum and 6,000 total Full Time Employment (FTE) in Scotland under the Baseline UK Supply scenario (refer to Table 18.33 of the Offshore EIA Report, Volume 2, Chapter 18).
6.3.5 During development, manufacturing, construction, and installation activities, the Proposed Development will inevitably draw some of its labour from outside of a number of local economic development study areas. However, within the local study areas referenced in the assessment for this phase of development (Invergordon, Aberdeen, Dundee, and Leith), the potential employment is estimated to be approximately 1,100 total FTE years (direct employment) under the Baseline UK Supply scenario (refer to Table 18.33 of the Offshore EIA Report, Volume 2, Chapter 18).
6.3.6 In conclusion, there will be a material positive benefit for the offshore wind sector, with significant beneficial impacts on employment generally but especially during the construction phase.
6.3.7 In addition, throughout the operation and maintenance phase, the assessment estimates that the Proposed Development would support around 320 jobs per annum and 11,200 in total (FTE years) locally, and 750 jobs per annum and 26,100 total (FTE years) in Scotland (direct, indirect and induced) (refer to Table 18.39 of the Offshore EIA Report, Volume 2, Chapter 18).
6.3.8 In conclusion, there will be a material positive benefit for the offshore wind sector, with significant beneficial impacts on employment generally but especially during the construction phase.
Investment (GVA)
6.3.9 During manufacturing, construction, and installation activities, the SIA sets out that the Proposed Development has the potential to generate £360 million (maximum concurrent GVA) GVA per annum and £450 million in total GVA, at the Scotland national level. This is equivalent to 80% of the 2019 offshore wind sector GVA in Scotland (refer to Table 18.45 and 18.46 of the Offshore EIA Report, Volume 2, Chapter 18).
6.3.10 For the local study areas (Invergordon, Aberdeen, Dundee and Leith), this impact is £90 million GVA per annum and £90 million in total GVA (refer to Table 18.45 of the Offshore EIA Report, Volume 2, Chapter 18).
6.3.11 During operation and maintenance activities, the Proposed Development has the potential to generate between £76 million GVA per annum and £2,600 million in total over the whole operation and maintenance period at the Scotland national level (refer to Table 18.51 in the Offshore SIA – Chapter 18). This is equivalent to 16.9% of the 2019 offshore wind sector GVA in Scotland (refer to Table 18.52 of the Offshore EIA Report, Volume 2, Chapter 18).
6.3.12 For the local study areas (Aberdeen, Montrose, Dundee, Methil, Burntisland, Rosyth, Leith and support harbours), this impact is £34 million GVA per annum and £1,200 million in total (refer to Table 18.51 of the Offshore EIA Report, Volume 2, Chapter 18).
Supply Chain Capacity, Capability & Skills Development
6.3.13 The socio-economics and tourism local study area for the Proposed Development (Invergordon, Aberdeen, Montrose, Dundee, Methil, Burntisland, Rosyth, Leith and support harbours east of Leith) has benefitted significantly and will continue to benefit from three of SSER’s offshore wind farms: Seagreen 1 (under construction), Seagreen 1a (in development) both in the former Firth of Forth Zone; Beatrice (fully operation) in northeast Scotland.
6.3.14 SSER has an established presence in the Firth of Forth. Berwick Bank will benefit from Seagreen 1 (1,000 MW) within the former Firth of Forth Zone, the largest and deepest offshore wind farm in Scottish waters, developed by SSER in partnership with Total. SSER and Total have addressed the challenges of deploying offshore wind in deep waters and established a long-term supply chain and material employment prospects to the Scottish job market, including 400 Scottish construction jobs and 60 during operation and maintenance.
6.3.15 The SIA explains that the north Scotland local study area for Berwick Bank already benefits from SSER’s substantial development of Beatrice Offshore Wind Farm (588 MW), Scotland’s largest-ever private sector infrastructure investment at time of construction. This has contributed significant expenditure in Scotland including £10m on development and construction, £1.4bn on operational lifetime spend and has created 370 jobs. Of primary benefit to Berwick Bank is SSER’s investment of £20m for the renovation of Wick Harbour, as well as the Open4Business portal where local suppliers can register for contractual opportunities.
6.3.16 By seeking to maximise the capacity at Berwick Bank, it brings forward the important opportunity and potential for supply chain investment in Scotland to meet Scottish policy by supporting an expanding domestic market in Scotland-based support services in readiness for both ScotWind and international project support.
6.3.17 Berwick Bank will support the continued development of the Scotland and the wider UK’s offshore wind clusters, particularly those located near the development, through engagement with local business networks in order to increase supply chain participation. In addition to job generation and investment, Berwick Bank will also support the development of skills which the offshore wind industry needs to flourish. Building up to 4.1 GW of offshore wind capacity by 2030 in Scotland will support a significant number of skilled jobs.
6.3.18 The Applicant will develop an Outline Employment and Skills Plan which will include the plans to enhance the benefits available to the local and national economies. The Applicant will promote the opportunities for local economic benefit associated with Berwick Bank through promoting opportunities:
> for the involvement of local companies in the construction and operation supply chain (this will also be addressed in detail at local, regional and national level in the Supply Chain Plan (SCP) which is a requirement of the CfD process); and
> for local residents to access employment opportunities associated with the construction and operation of the wind farm.
6.4 Community Benefit Fund
6.4.1 The Applicant is also committed to the creation of a Community Benefit Fund following the grant of consent for the Project. A Berwick Bank Community Benefit Fund would be established in partnership with local stakeholders to ensure that local communities help set the priorities for the fund, as well as decide on what gets funded. The details of the Community Benefit Fund would be established post the grant of consent. Ahead of establishing any formal Fund, the Project team are keen to support local initiatives where possible and have invited local stakeholders to discuss opportunities directly with the Project team. To date the Project has supported various local organisations and initiatives such as the North Berwick Fringe By The Sea Festival, the Scottish Seabird Centre and the National Merlin Rocket Yachting Championship, held in East Lothian. In addition to this the Project team are working alongside local education partners to explore a variety of Science, Technology, Engineering and Mathematics (STEM) benefits that the Project can bring to the East Lothian area. The Project team are members of the East Lothian Industry and Education Partnership and are also members of the Mid and East Lothian Chamber of Commerce.
6.5 Socio-Economic Conclusions
6.5.1 It is clear from the above that the Proposed Development will result in considerable employment, investment, skill development and supply chain related benefits – both during the construction and operational periods and at local and national levels.
6.6 Conclusions in relation to overall Project Benefits
6.6.1 Significant support for the Proposed Development can be drawn from understanding the extensive positive renewable energy generation, climate change mitigation and socio-economic effects that would arise from the Proposed Development. Support can be drawn from relevant legislation and policy including the MPS, wider national marine and energy policy and the Development Plans including NPF4. The benefits of the Proposed Development will considerably advance a number of UK and Scottish Government renewable energy, climate change, economic and marine policy objectives and statutory target obligations.
6.6.2 The predicted benefits should be afforded substantial weight in the determination of the application for Section 36 consent and associated marine licences.
7. Conclusions
7.1 Introduction
7.1.1 This Chapter provides the overall conclusions on the general accordance of the Proposed Development with the relevant legislative and policy considerations to which the decision maker must have regard in determining the Applications for Section 36 Consent and the associated Marine Licences. Attention is also drawn to substantial body of renewables and marine relative policy which have been identified as material to the determination and have a statutory footing.
7.2 The Electricity Act 1989
7.2.1 The Scottish Ministers are required by paragraph 3(2) of Schedule 9 to the 1989 Act to consider the desirability of the matters mentioned in paragraph 3(1)(a) and the extent to which the Applicant has fulfilled the duty imposed by paragraph 3(1)(b). The list in sub-paragraph (a) contains matters all of which are likely to be relevant to the grant of consent and have been addressed in the EIA Report.
7.2.2 The information that is contained within the individual topic sections of the EIA Report and in additional environmental information therefore enables Scottish Ministers to be satisfied in relation to Schedule 9. The EIA Report also shows that the detailed work undertaken in the formulation of the EIA has confirmed and provides confidence that the Project would be undertaken in an environmentally acceptable manner.