Hornsea Project Three Offshore Wind Farm

The views expressed in this page do not represent those of the Planning Inspectorate. This page consists of content submitted to the Planning Inspectorate by the public and other interested parties, giving their views of this proposal.

Hornsea Project Three Offshore Wind Farm

Received 20 July 2018
From Brodies LLP on behalf of Spirit Energy North Sea Limited


‘Spirit Energy’ is the trading name used by Spirit Energy Limited and its subsidiaries which collectively as a group conduct European oil and gas operations.
Spirit Energy (“Spirit”) is headquartered in the UK and collectively operates and/or holds interests in 27 producing fields and more than 70 exploration licences across the UK, Norway, the Netherlands and Denmark.
Spirit Energy North Sea Limited (UK Company Number: 04594558), Spirit Energy Resources Limited (UK Company Number: 02855151) and Spirit Energy Nedlerland B.V. (Company Number: 34081068) are each entities operating under the ‘Spirit Energy’ trading name. Each of these entities own and operate assets located in the Southern North Sea (on both sides of the UK/Netherlands median line) including platforms, pipelines, seabed infrastructure and licensed blocks. Spirit has interests that lie within or near to the application area.
Spirit Energy North Sea Limited wishes to be registered as an Interested Party in the examination of the Hornsea Project Three Offshore Wind Farm.

• Spirit has experience of operating near to the eastern Irish Sea Walney Wind Farms. The Hornsea 3 array leading edge is significantly closer to Spirit’s assets – at half the distance than Spirit currently experience in the Irish Sea.
• The eastern leading edge is in close proximity to our operational Greater Markham Area interests; (gas platforms: Chiswick, Grove and J6A and subsea infrastructure: Kew and Grove G5).
• Spirit consider safe and efficient gas production would be significantly hindered through access constraints affecting ability to undertake maintenance interventions and emergency repairs. Capacity to develop existing licences and decommission existing infrastructure would also be restricted.
• The economic viability of the whole Greater Markham area assets in both UK and Netherlands waters are reliant on being able to operate without hinderance to the maximum possible capacity.

Shipping and Navigation
• Vessels supporting Spirit platforms, subsea infrastructure and pipelines require sufficient sea room to operate. This includes setting up and being on standby outside of 500m safety zones, working in ‘drift off’ positions and being accessible by helicopter.
• If the leading edge of Hornsea 3 is too close to our existing assets, there is potential for our vessels to be in a ‘drift on’ situation with any Hornsea 3 construction vessels/ wind turbines or for the windfarm vessels to be in a ‘drift on’ position to our assets creating a collision or allision risk with insufficient time to react.
• Platform and vessel Radar Early Warning Systems (REWS) are identified as impacted by individual and cumulative wind turbine signatures, significantly reducing their effectiveness and leaving insufficient threat response time.
• Access for the maintenance or decommissioning of subsea infrastructure and pipelines is not properly considered in the application. This may be for a short notice intervention of days or a managed campaign of several months.
• Third party shipping is likely to be displaced more closely to Spirit assets if they track around the eastern leading edge of the array. Further displacement by fishing vessels would be caused by the Markham’s Triangle MCZ. Vessels transiting around the south east tip of the proposed array are likely to be drawn toward the Grove platform as a fixed way point. There would be a cumulative impact of increasing vessel numbers (displaced shipping vessels and Hornsea 3 vessels) along with hindered reduced effectiveness of REWS.
• Proximate windfarm piling would interfere with safety of diving operations that may be required at any of our assets. This has not been considered as part of the application.

• The application indicates that due to the significant number of flights utilised by windfarm developers, available airspace may be affected. Whilst already hindered due to weather any additional constraint adds to the cumulative burden and has significant operational impacts.
• Flights from Humber to the Spirit Greater Markham Area would be made logistically difficult due to the collective effect of the Hornsea projects. Flights from Norwich would need to be routed around Hornsea 3 adding around 10km to each Chiswick flight.
• In poor flying conditions and in the event of missed approach landings, a safe distance in all directions is required before obstacles are encountered.
• Helicopter operations supporting J6A, Chiswick and Grove gas platforms are identified as having constrained airspace. Access is needed at all times when the platforms are manned and helicopters are considered the primary means of escape.
• Helicopter operations supporting mobile rigs undertaking maintenance and decommissioning activities for platforms, pipelines and subsea infrastructure have not been appropriately evaluated in the application. These may need to be located anywhere Spirit has infrastructure including closer to the turbines and supporting infrastructure than the application has considered.

• A number of licences held by Spirit are wholly or largely within the application area or proposed exclusion zones that would be difficult if not impossible to progress if windfarm construction commenced.
• An incorrect assumption has been made that licences are not developed in their later terms. Whilst one operator may relinquish a licence they may be re licenced by the Oil and Gas Authority. The proposal would have the effect of impeding future exploration and production; sterilising UK hydrocarbon resource.
• It is not clear within the application what proportion of the windfarm development would be possible without constraining existing oil and gas infrastructure. This would allow valuable discussion on compromise.

Risk assessment methodology
• Throughout the Hornsea 3 application, risk assessment assumptions have allowed issues to be screened out, whereas Spirit consider many of the same issues as important and requiring additional scrutiny and active management.

• Spirit continues to be fully committed to engaging with Orsted throughout the planning, development and operation of their projects.
• Spirit is liaising directly with OPRED as regulator and Oil & Gas UK as industry body to ensure they remain fully informed as to the potential implications on its activities.

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