Consultation response: September 2016
Offshore windfarm project in the Bay of St. Brieuc
Ailes Marines SAS
Introduction
The Government of Jersey (GoJ) welcomes the opportunity to comment on the proposals for the development of a windfarm in the Bay of St. Brieuc.
It acknowledges the willingness of the Préfet des Côtes d’Armor to seek the Government of Jersey’s views in accordance with the requirements of the Espoo Convention, 1991 (to engage on the assessment of the impacts on the environment of transboundary projects). It would also like to express the wish that this level of engagement and partnership might continue and develop, not only as a result of this particular project, but also in relation to any future initiatives.
Background and context
It might be helpful for the enquiry to note that Jersey’s status as a territory of the Crown gives the Island constitutional rights of self-government and judicial independence. Although outside the EU, the Government of Jersey has requested the extension to the Island of a number of the EU and international conventions to which the UK is a party, including those relating to human rights, international sanctions and multilateral environmental agreements (MEAs).
It is also relevant to note that all obligations concerning fishing in the waters affected by the development proposal are set out in the Agreement between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the French Republic concerning fishing in the Bay of Granville (Treaty Series No.9 (2004))[1] and that the views of the Joint Management Committee, as established under the Granville Bay Agreement, should be sought and considered separately.
Jersey's territorial waters extend to 12 nautical miles or to the median line between France and Guernsey and cover almost 2,000 square kilometres. Its coastal and marine areas are of outstanding scenic, historic and cultural value.
The international importance of Jersey’s coastal waters is recognised by the fact that almost 190 square kilometres of inter-tidal habitat, spread across Jersey’s south-east coast and offshore reefs, are designated as wetlands of international importance under the Ramsar Convention[2]. Of particular interest and relevance to the assessment of this proposal is the offshore reef system of Les Minquiers, one of Jersey’s Ramsar sites, comprising a group of small islets; an inter-tidal zone; and a submerged plateau, covered by water that is less than 10 metres deep, of over 100 square kilometres to the south of the Island of Jersey, and in relatively close proximity to the development site.
This response is based upon an understanding of potential transboundary impacts upon the Island’s territory and operations within it; its MEA commitments; and the core principles and values of some of the Island’s strategic policies.
It has been prepared against the context of the English non-technical summary of the impact assessment study[3]. Some consideration has also been given to the documents (in French) that form the Dossier for the EIA and the Avis délibéré[4] presented by the Autorite environmentale (Ae).
Understanding of the proposal
A summary of the Government of Jersey’s understanding of the proposal is also provided to provide clarity and for the avoidance of doubt.
The proposed windfarm spans some 75km² in the Bay of Saint-Brieuc, lying 37km from the south coast of Jersey. The windfarm will include 62 wind turbines, placed in seven rows; an orientation based on the direction of ocean currents, prevailing winds and established fishing practice. Each turbine will stand at approximately 262m from base to tip, with approximately 216m of the structure standing above sea-level. The wind turbines are to be spaced 1,000m apart and 1,300m between each of the seven rows. The rotor diameter will be 180m.
The proposal outlines that each turbine will be set upon four piles and a ”jacket” foundation that will support a lattice structure below sea level, and then connected to a transition piece that will attach the turbine to the base. The metal lattices do not require prior work on the sea bed and take up little space on the seafloor, and have minimal impact on the currents and swells. Jackets are also considered easier to dismantle and recycle than other foundations. It is of note that 20 of the foundations will have scour protection installed, mainly to the south and east of the site.
There will be a cable network that runs between each turbine, of which will be buried when the sea bed conditions are appropriate – in areas where this will not be possible, the cables will be protected by rock fill. There will be an offshore sub-station constructed in the centre of the windfarm, which will transfer the electricity to two export cables that will land on Caroual Beach in Erquy, France.
A met mast will be placed on site to monitor weather conditions.
The anticipated offshore construction will begin in 2018 and the windfarm operational by 2020.
Impact assessment commentary
The Government of Jersey is committed to the Island reducing its carbon emissions in line with Kyoto objectives and recognises that globally, utility scale renewable energy is critical to achieving a decarbonised economy and preventing dangerous global climate change. In principle, therefore, the Island is supportive of France’s aspirations to develop offshore renewable energy.
GoJ welcomes the opportunity to comment on the proposals for the construction of a windfarm in the Bay of St Brieuc: owing to the proximity of the proposed development to the territorial waters of the Island, its principal concerns relate to the trans-boundary implications of the development. The Government of Jersey considers there to be five key issues requiring consideration around the following themes:
- Visual amenity and sense of place
- Impact on heritage assets
- Impact on environmental assets
- Transport impacts
- Futureproofing
These are examined in greater detail as follows:
- Visual amenity and sense of place
Visual amenity: seascape impact:
The impact of the proposal upon the visual amenity of the seascape, when viewed from various perspectives, is an important material consideration. The apparent visual impact from the Island of Jersey has been shown in CGIs from the south coast of the Island where visual representations are provided in the Non-Technical Summary from both La Corbiére and Noirmont. There is, however, no visual representation provided from Les Minquiers and neither has it been possible to assess the night-time beaconing aspect of the proposal from any perspective of Jersey’s territory as this detail is not contained within the NTS.[5] The comments made in relation to this aspect of assessment are thus subject to these constraints.
The visual impact of the proposal when assessed at a 35km radius from the development is stated as low (page 77). Whilst the turbines are likely to be visible from the island’s south coast (which is 37 km distant), this is only expected to be on a clear day and at night, and is likely to be at a minimal scale on the horizon due south. This may be particularly apparent at night when the beaconing lights are likely to be more prominent.
Despite the apparent low scale impact from island’s south coast, it is nevertheless regretted that the distant outlook from Jersey’s southern shores will be disrupted by the presence of the turbines, which may contribute to a degree of perceived urbanisation on an otherwise undeveloped horizon.
Les Minquiers reef is a lot closer to the development site than ‘mainland’ Jersey and appears to be at a similar distance from the development as Cap Fréhel (shown on the chart on page 39). And whilst there is no CGI perspective from Les Minquiers, its geographical proximity and the assessment of visual impact from Cap Fréhel would suggest that the turbines will be visible.
The French Coast and the Island of Jersey sit within the seascape setting of the Les Minquiers reef and form part of the surroundings in which the buildings and landscape of the reef are experienced. It is thus considered that the visual impact of the proposed development on Les Minquiers will be average by similar measure, particularly at night when the warning lights will be visible: GoJ would expect formal assessment of this aspect to inform decision-making.
Sense of place
Whilst the visual impact of the proposed development may be considered to be average, there is a need to consider the less tangible potential effect on the qualities of the sense of remoteness and place of Les Minquiers. This is an experiential issue and one which will serve to potentially undermine the nature and character of Les Minquiers as a small islet, with a collection of small, simple stone-built huts, which exists remotely from other forms of development. The extent of this particular impact remains to be assessed. GoJ would expect an objective written assessment to be prepared to inform the decision-making process which should attempt to quantify the extent of any detrimental impact on the quality of the sense of place and character of Les Minquiers.
The NTS of the EIA acknowledges Jersey’s tourism industry that has some reliance upon the character of the coastline to attract visitors but makes a suggestion that the presence of an offshore windfarm should not lead to a decline in tourist numbers. On the contrary, there is a suggestion in the NTS that the presence of the offshore windfarm may be an opportunity to initiate tourist activity around offshore renewable energies, thereby enhancing exiting tourist activities. Whilst the overall impact has, thus, been suggested as a positive one, this is not supported by any evidence and can only thus, be regarded as a statement of view.
- Impact on heritage assets
Buildings and places
La Maitresse Ile, the principal islet of Les Minquiers, is a potential Listed Place (GR0242) which is protected because the islet is of archaeological and historical interest as a prehistoric occupation site and which has associations with nineteenth century quarrying activity and traditional fishing in the area. The stone-built huts, although altered over the years, are of interest as simple vernacular cottages of a type with few surviving in Jersey.
The Landscape Assessment does not review the impacts of the proposed wind turbines from Les Minquiers nor review its landscape character and inter-visibility with the mainland of the French coast. Whilst the built heritage on the islet is modest, the heritage value is significant and it is a place of cultural and tourism value to Jersey.
As stated above, there is considered to be a need to better assess and understand the impact of the proposed development upon Les Minquiers, to include its heritage value: GoJ would expect an objective written assessment to be prepared to inform the decision-making process which should take into account the significance of the historic asset and its setting, and attempt to quantify the extent of any detrimental impact on both the heritage asset as well as the quality of its sense of place and character.
Underwater archaeology[6]
The NTS identifies that the nearest shipwreck is located approx. 2.55km from the development site and declares that no impact on known shipwrecks of archaeological heritage value is expected.
Shipwrecks are not currently formally identified and/or designated in Jersey waters and it is not, thus, clear as what potential there may be for other wreck sites that are not formally identified to be affected by the proposal.
The understanding of the underwater archaeological heritage of Jersey and its archaeological context is an area of current academic interest and research: work is ongoing to better understand the Island’s deep historic past during a period when sea levels were completely different from what they are today. The location of the proposed development is internationally significant in terms of early human archaeology. A rich coastal and inter-tidal record of prehistoric occupation, spanning at least 300,000 years through to the Mesolithic and Early Neolithic, has been documented for Brittany, the west coast of Normandy and the Channel Islands, especially that of Jersey.
Understanding the development of this landscape in terms of sea-level, palaeo-climate and palaeoenvironmental change is, therefore, important for both contextualising known archaeological sites, but for also documenting the scope and scale of human activity in the now submerged landscapes.
It is not clear to what extent the impact of the proposal upon underwater archaeological heritage has been assessed and reviewed. GoJ would expect the following level of archaeological assessment to be undertaken by competent authorities in order to inform the potential archaeological impact of the proposed development:
• assessment of geophysical and bathymetric data to model sea bed topography, model sea level change and identify sediment capture points;
• geoarchaeological characterisation of deposits which will be impacted upon during the construction. Detailed geological mapping feeding directly into enhancing existing mapping;
• assessment of palaeoenvironmental potential and subsequent analysis leading to characterisation of past environments; and
• if considered necessary on the basis of the above, targeted assessment of terrestrial sediment bodies for evidence of past human activity.
There is considered to be considerable benefit for archaeological survey data to be shared to promote a greater understanding of the archaeology of the wider area and for protocols to be developed with GoJ in order to effect monitoring of change and the mitigation or remediation of impact upon marine archaeology where necessary and appropriate to do so. GoJ would seek to secure consultation and engagement on the detailed construction/decommissioning and associated environment management plan prior to the commencement of the construction/decommissioning of the windfarm. This will help to ensure all proposed monitoring and mitigation measures are understood and agreed and will provide GoJ with the necessary assurance that any transboundary impacts can be sufficiently considered and appropriately managed.
- Impact on environmental assets[7]
Biodiversity
With regard to biodiversity, the views of the Government of Jersey are consistent with the findings of the Avis presented by the Ae.
GoJ endorses the key issues highlighted by the Ae and the important recommendations suggested to inform debate as part of the Public Enquiry. It would like to see these recommendations adopted to inform all stakeholders, public debate and compliance with environmental commitments.
GoJ agrees that the major ecological issues within the windfarm zone are:
• impacts of noise and loss of habitat for marine mammals;
• impacts on marine birds from collision, loss of habitat and the “barrier effect” that the parc may create;
• impacts of construction on all marine species especially at a juvenile stage;
• the as yet unquantified impacts from the cumulative developments of other projects at sea; and
• a lack of existing scientific data to allow a full assessment of the impact of windfarms at sea on associated species and habitats.
Whilst the EIA does provide an extensive assessment of the existing ecology within the construction zone and the broader maritime environment that overlaps territorial waters it is uncertain as to whether the impacts on the Les Minquiers Ramsar area have been fully considered. This proposal is considered to be an identified “threat”, as outlined in the management plans for this Ramsar site.
Whilst it is acknowledged that the ecological information currently available in relation to Les Minquiers is limited it is considered that more work needs to be done to assess the impacts on:
- seascape (as already identified above);
- species presence and behaviours around the waters of Les Minquiers (notably of marine mammals and seabirds).
A more comprehensive assessment of the impacts on species characterised by the Natura 2000 designations is considered to be important. It is relevant to note that Jersey and indeed some of the other Channel Islands now have a Biological Records Centre[8] which may well be able to supplement the EIA and allow the issues around impacts to be explored more fully.
There is considered to be considerable benefit for biodiversity survey data to be shared to promote a greater understanding of the biodiversity of the area and for protocols to be developed with GoJ in order to effect monitoring of change and the mitigation or remediation of impact upon biodiversity where necessary and appropriate to do so, especially during the construction and decommission phases of the proposed development. This will help to ensure all proposed monitoring and mitigation measures are understood and agreed and will provide GoJ with the necessary assurance that any transboundary impacts can be sufficiently considered and appropriately managed.
Fisheries management
The GoJ notes the references to commercial fishing and supports the recommendations of Ae concerning these activities.
In addition, GoJ would wish to highlight the need to secure the views of the Joint Management Committee, as established under the Granville Bay Agreement, to determine the potential impact of the proposal on fisheries management and commercial fishing activity.
Air and water quality
GoJ notes that the impact upon air quality is expected to be limited to the discharge of emissions from boat engines, mainly during the construction and decommission phases of the development. The air quality impact has been listed as negligible for each phase.
The EIA NTS indicates that there are a number of elements to the proposed windfarm that have potential to cause impact to water quality. In particular, volumes of suspended sediment are expected during both the construction and decommissioning phases, in addition to the discharge of metallic chips from sawing in the decommission phase. The NTS outlines the adverse impact to be none, negligible and average for each of the project phases and sets out a methodology for monitoring water quality.
GoJ consider it to be both appropriate and beneficial for monitoring data relating to the impact of construction and decommissioning upon water quality, in particular, to be shared and for protocols to be developed with GoJ in order to effect the mitigation or remediation of impact of the proposed development where necessary and appropriate to do so. This will help to ensure all proposed monitoring and mitigation measures are understood and agreed and will provide GoJ with the necessary assurance that any transboundary impacts can be sufficiently considered and appropriately managed.
- Transport impacts
Maritime operations
It is noted that each turbine will be fitted with a beacon and allocated a number that will be visible day and night, which is intended to aid vessel navigation whilst in the wind farm. The turbines located at the boundary of the farm will also be fitted with a yellow beacon for vessels to locate the windfarm at night. GoJ does not have any concerns in relation to the impact of the development with regard to maritime operations.
Radar: aviation and meteorological
When wind turbines are grouped in wind farms they can have a significant effect on radar and specifically on radar used for aviation as they are typically designed to show only moving objects and filter out anything that is stationary. The spinning blades of wind turbines can appear on the radar screen as false "targets". The interference (or "clutter") generated by the turbines can cause legitimate targets to disappear.
Following presentations in 2013, Ports of Jersey (PoJ) were provided with accurate coordinates of the proposed development in order that it might be plotted on radar maps and its location evaluated relative to airways and routes. The assessment undertaken at that time was that, at this location, there was little or no impact on Jersey’s aviation radar.
Given the passage of time there is a requirement for Ports of Jersey to ensure that current regulatory requirements are met. This requires a review of aviation safety impacts of the current proposal, and in order for this to be undertaken, there is a need for the revalidation of mapping and coordinate data of the current proposal in order that it might be assessed in relation Jersey’s current radar. It is expected that this data and assessment would be undertaken by the developer of the proposal, and the data shared with GoJ, in order to demonstrate little or no impact upon the use of radar and the safety of aviation. In the event of any adverse impact, GoJ would seek to ensure that mitigation or remediation of impact, subject to the approval of GoJ, was effected by the developers to mask out any ‘clutter’.
GoJ would expect similar considerations to apply to the assessment of the proposals upon weather radar and for the developers of the proposal to engage with both GoJ and Meteo France to effect appropriate mitigation, where necessary and appropriate to do so.
- Future proofing
Decommissioning
GoJ is encouraged to see that there is a planned decommission of the proposed windfarm at such a time the farm serves no viable continued use. The NTS states that the owner will dismantle the entire installation insofar as technically feasible (e.g. it will not possible to retrieve piles from rock). It is planned that two years before the end of the concession, a study will be launched optimising dismantling conditions and site restoring, assessing the impact on the environment, stakeholders and maritime safety.
GoJ would seek to secure an assurance that it would be party to any process of decommissioning to ensure that the impact of any transboundary effects might be considered and mitigated by agreement at the time, as is necessary and appropriate to do so.
The Government of Jersey would seek a further assurance that the French government would, in the event of any financial difficulties being experienced by the owner of this project, have in place appropriate safeguards to ensure that the decommissioning proceeds in an appropriate manner.
Future windfarm proposals
Jersey’s Energy Plan commits the GoJ to continue to explore the potential for utility scale offshore renewable energy projects and the Revised 2011 Island Plan makes provision for offshore utility scale renewable energy development within Jersey’s waters. Given the proximity of this proposal to Jersey’s territorial limits and the optimal optimum conditions for the development of a utility-scale windfarm, GoJ would welcome an assurance that this current proposal would not prejudice the development of a proposal of a similar nature within its own jurisdiction.
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