Windfarm near Les Ecrehous

STATES OF JERSEY

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WINDFARM NEAR LES ECREHOUS

Presented to the States on 1st February 2005 by the Policy and Resources Committee

STATES GREFFE

PROPOSITION

THE STATES are asked to decide whether they are of opinion

to a g ree that the French Government be requested to consult with the Island Authorities on the proposal to

construct an offshore windfarm in French territorial waters off Saint-Rémy-des-Landes, Normandy, before any final decision is taken.

POLICY AND RESOURCES COMMITTEE

REPORT

Background to the windfarm project

In June 2003 the Island Authorities received correspondence from a company advising them of a proposal to build a windfarm in French territorial seas off Saint-Rémy-des-Landes, Normandy. The designated area is close to Les Écrehous reef which is within Jersey's territorial limits.

It is acknowledged that the French nation is committed to the production of sustainable energy. While generally supportive of the principle of sustainable energy, the Island Authorities have received only limited official communication about the windfarm development proposals.

1. I n O ctober 2003 States Membershad the opportunity to attend a presentation on energyproductiongiven by Dr. ClaudeGatignol,Vice-Présidentof the Conseil Général de la Manche and also Président of the Groupe d'Études sur les Énergies. The particular focus of the presentation was nuclear power but reference wasalsomade to possibleplans to build a windfarm near the Écrehous.
2. In October 2003 the Island Authorities wrote to the Departmentof Constitutional Affairs (DCA) raising several issues ofconcernto the IslandAuthorities in relation to the proposed development.
3. I n February 2004, theFrenchGovernmentputout an invitation to tender for proposalsfor a national windfarm project.The project involves the building of several windfarms for whichsites are to bechosen. Onepossible location is the areaoff the Écrehous reef.
4. O n 27th April 2004 theDCAforwarded a response to the Island Authorities' letter receivedthrough official channels from the French Ministry of ForeignAffairs. This outlined the proposed timetable and criteria for accepting tenders, and the statutory duty of the French Government to consult after the opening of a public enquiry.
5. O n 1st July 2004 the Island Authorities wrote to theDCAnoting that confirmation had been received from the French Ministry of Foreign Affairs that both the United Kingdom and Frenchgovernmentshave international obligations under the Convention on EnvironmentalImpactAssessment in a Transboundary Context (the "ESPOO" Convention) and the Conventionfor the Protection oftheMarineEnvironmentof the North East Atlantic (the "OSPAR" Convention). The Island Authorities confirmed that they would wish to participate fully in any consultation process.
6. O n 5thNovember 2004, the Conseil GénéraldelaManche informed the Island Authorities of a decision recorded by theAssemblée Départementale on 6th October 2004. TheAssemblée requests that the Écrehous project bewithdrawnand regrets that sufficient opportunity to comment has not been granted to interested parties in thearea.

Most recently, States Members, the public and officers of the relevant departments have received a presentation by the company that is currently tendering to carry out the proposed development off Saint-Rémy-des-Landes. This has provided the opportunity to seek more detailed information on the proposals and, to some extent, moderated some of the initial public concern. Following the presentations, there was a measure of public support for the concept of environmentally sustainable energy production by windfarms. However, there remain some important issues that have yet to be resolved, as detailed below.

Current concern

The tender period has now closed for potential developers of offshore windfarms in a number of locations around the French coast, and it is now understood that a technical proposal will be made in France on 15th February 2005 as to the most suitable sites for development.

Further approvals will, however, be required from the French authorities, following an environmental impact assessment and a public enquiry in France. These include authorisation to generate electricity for the national grid, planning consent to develop the site and permission to lease a section of the seabed.

Although the proposed site off the Écrehous Reef is outside Jersey's territorial waters, its proximity to the Island's territorial limits means that there is likely to be a transboundary impact should the development go ahead. It is the contention of the Island Authorities that they should be afforded the opportunity to contribute to the environmental impact assessment and to consult on the proposals with local interested parties and thereafter submit their conclusions to the French Government before a final decision is made with regard to the proposed development.

Issues for consideration

The reasons put forward for concern include the possible damage to the marine environment, the visual intrusion of the wind turbines, noise produced by the turbine blades, interference with aviation radar and consequent risks to air traffic safety, possible economic effects on the fishing industry and hazards for maritime navigation.

Following meetings with the potential developers, the concerns about possible damage to the natural environment have been to some extent addressed. Evidence from other similar offshore developments has not demonstrated significant harm arising for the marine flora and fauna, or birds in the vicinity of the turbines. If anything, there is evidence that marine life may be enhanced by the submarine structures and 50-metre exclusion areas around each turbine. The potential developers have, in consultation with local ornithological groups, taken care to observe the existing migratory bird routes and have revised the proposed windfarm location accordingly. Decommissioning arrangements for the windfarm are also a statutory obligation for which appropriate funding and environment remediation plans are required.

Proximity of a windfarm to Les Écrehous was also a concern, particularly with regard to the sensitivity of the unique environment of this proposed Ramsar site. As a result, the developers have proposed re-locating the development further south, to a position some 10  kilometres (km) from Les Écrehous and 20  km from Jersey's south-east coast.

The proposed relocation of the windfarm site would also remove it from the usual routes for maritime navigation, both for private boats and small passenger vessels, between Jersey and Carteret or Portbail.

Whilst there were concerns about fishing, following discussion with Jersey fishermen it is considered unlikely that the proposed location would have any significant impact on the types of fishing activities currently carried out in the area.

The level of noise produced by the windfarm, estimated to be about 50  decibels at the base of a turbine when operating, is not considered to be a significant issue. At a distance of a few km, the noise would be dissipated substantially and, when the turbines are operating, their noise is masked by the ambient sea and wind noise.

The most significant of the remaining concerns are described below –

1. The actual scale of the proposed windfarm isconsiderable. It isunderstood to consist of a plan to generate 80MWofpower, from 20 to 23 wind turbines with a hub height at 90 metresabovemeansea level, and rotor blades a further 60 metres in length.

It i s c onsidered that a development of this scale would have a significant visual impact, even at a distance

of 20  km from Jersey. The wind turbines would be visible during the day and especially at night due to illumination in an area that is largely free of light pollution.

2. T h e possible effects on aviation areof particular concern,due to theheight of the turbineswhich would clearly be a hazard toaircraft flying at low level, and would require a restriction area to prevent collision. The turbineswouldneedto be conspicuously lit with flashing strobe lights for safety reasons.

T h e re could be serious effects on 2 important aeronautical radars, located on the northern cliffs of Jersey and in direct line of sight' of the proposed windfarm installation. These radars serve Jersey and Guernsey

airports  and  also  the  Channel  Island  Control  Zone,  the  French  national  radar  network, Réseau  de

Télécommunication de la Navigation Aérienne, and the London Terminal and Area Control Centres at West Drayton and Swanwick.

R a d a r reflections from the windfarm towers and rotating turbine blades are certain to interfere to some

extent with the primary radar, which has a range of 80  nautical  miles, and may produce reflected o distorted radar images together with masking some low-flying aircraft in the secondary radar system, range 256  nautical  miles. The secondary radar antenna is tilted down specifically to enhance the detection of targets at low altitude and, in the absence of any ground terrain to absorb incident radar energy and the probability of specular reflections from the water, this is likely to compound the problems. The Airport authorities would need to take considerable measures, although it is uncertain what these could be, to ensure aviation safety is not jeopardized.

I f t h e windfarm development was to proceed, extensive, and probably costly, research and modelling

would be required by the airport authorities, radar systems suppliers and the windfarm installers to identify the magnitude of these air traffic problems and to quantify the effectiveness of any amelioration proposals. There is no single simple software solution to remove these deleterious effects.

Conclusion

The States are asked to note that both the United Kingdom and French Governments have international obligations under the Convention on Environmental Impact Assessment in a Transboundary Context (the "Espoo Convention"). The proposal to construct an offshore windfarm at a location near Saint-Rémy-des-Landes is considered to be a development that may have a significant adverse transboundary impact on Jersey, and is within the scope of that Convention.

The States are  asked  to agree  that the French Government should be requested  to consult with the Island Authorities on the proposals before any final decision is taken on the development of a windfarm in this area.