Windfarm near Les Ecrehous

STATES OF JERSEY

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WINDFARM NEAR LES ECREHOUS

Lodged au Greffe on 18th January 2005 by the Policy and Resources Committee

STATES GREFFE

PROPOSITION

THE STATES are asked to decide whether they are of opinion

( a) to express their concerns to the French Government about plans currently being considered by

them to construct an offshore windfarm in French territorial waters off Saint-Rémy-des-Landes, Normandy, a location near the Écrehous reef, and thereby to indicate their support for the position of the Assemblée Départementale de la Manche of 6th October 2004 in opposition to the development; and

(b ) to agree that the French Government be requested to consult with the Island Authorities on the

proposals 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 French 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-Président of the ConseilGénéraldelaManche 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 ConseilGénéraldelaManche informed the Island Authorities of a decision recorded by the Assemblée Départementale on 6th October 2004. The Assemblée requests that the Écrehous project bewithdrawnand regrets that sufficient opportunity to comment has not been granted to interested parties in the area. A series of supporting argumentsisincluded in the text of the decisionand reference is made to the fact that both the local Frenchauthoritiesand the States of Jersey recognise the ecological sensitivity of the area.

Current concern

It is believed that the likely timescale of events concerning this project could result in a limited period in which the Island's views can be put forward for consideration before a final decision is taken by the French Government.

The tender period for the windfarm project has now closed. A public consultation of the sort that would be held in the United Kingdom is not planned, although it is understood that there will be an administrative procedure to submit views to an enquiry. However exact details of this procedure and the timescale involved are unclear.

It is now understood that a decision will be made in France on 15th February 2005 as to the winning sites for development.

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 highly 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 an 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 regards to the proposed development.

Issues for consideration

The reasons for the Island Authorities' concerns include the likelihood of damage to this sensitive marine environment, the visual intrusion of the wind turbines, interference with aviation radar and consequent risks to air traffic safety, possible economic effects on the fishing industry and hazards for maritime navigation. The most significant of these concerns are described below –

1. T h e actual scaleof the proposed windfarm is considerable. It is understood to consist of16to20wind turbines with a hubheightat 100 metresabovemeansea level, and rotorblades a further 60metresin length.
2. T h e construction of a windfarm and the electromagnetic radiation subsequently generated is likely to adversely affect the diverse species for which the shallow sandbanksareanimportant habitat. These include sand-eels, a widerangeof fish-eating seabirds and migratory populationsofspider-crabsand various fishspecies.Thepotentialeffects on seabirds, such asgannets, terns and cormorants, include alteration oftheir food supply, disturbance byconstruction and operation, and riskof collision with the rotor blades. It is also possible that seismic surveys,construction and operating noisewould affect marine mammals,includingwhales, seals, and a significant local populationof bottlenose dolphins (up to one- third of the total "U.K." population reside in local waters).
3. F u rtherenvironmentalconcerns include arrangements for disposalof construction waste and the effectson local hydrography.
4. B o th the UnitedKingdom and Francehave international obligations regardingtheconservationof such habitats, for exampletheBonn convention onmigratory species of wild animals, the African-Eurasian waterbird agreement, the Bern convention on the conservationofEuropean wildlife and natural habitats, and the E.C. Habitats Directive.
5. I t isbelieved that the development would have a significant visual impact. Thepossibledevelopment zones lie approximately10 km. from Jersey's north-eastcoast in anarea of outstanding seascape. A Guide to Best Practice in SeascapeAssessment,publishedby the Marine Institute in 2001, suggests that a distance of15 km.maybethelimit of visual significance along the coast.Thewindturbineswouldbe highly visible during the dayand at nightdue to illumination in an area that is largely freeoflight pollution.
6. T h e possibleeffectsonaviation are of particular concern,dueto the height of the turbineswhichwould 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.
7. T h ere could be serious effectson 2 importantaeronautical radars, located on the northern cliffs of Jersey and in direct line ofsight' of the proposed windfarm installation. These radars serve Jersey andGuernsey airports and also the Channel Island Control Zone, the French national radar network, Réseau de Télécommunicationde la NavigationAérienne, and theLondonTerminaland Area Control Centres at West Drayton andSwanwick.
8. R a dar reflections from the windfarm towersand rotating turbine blades are certain to interfere to some extent with the primary radar, whichhas a rangeof 80 nautical miles, and mayproduce reflected o distorted radarimages together with masking somelow-flying aircraft in the secondary radarsystem, range 256 nautical miles.Thesecondaryradarantenna is tilted down specifically toenhance the detection of targets at low altitude and, in the absence of any ground terrain to absorb incidentradarenergyand 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. 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 ameliorisation proposals. There is no single simple software solution to remove these deleterious effects.

9. T  h e areaaroundthe Écrehous reef is a popular resort area used by boaters andfishermen.In addition there are several ferry routes that pass through the area including some of those linking Jersey and Normandy and, at times, a St.  Malo-U.K. ferry.

Conclusion

The States are asked to consider this Proposition and to express their concerns to the French Government about plans currently being considered by them to construct an offshore windfarm at a location near the Écrehous reef. Further they are asked to request the French Government that they consult with the Island Authorities on the proposals before any final decision is taken, and to indicate their support to the Assemblée Départementale which opposes the development of a windfarm in this ecologically sensitive area.