Since our update back in October 2023, a lot of change has been happening and we wanted to share the most recent communications we have had with the team at Whitecross as of this morning (15/07/2024).
We have asked specific questions around beach access, the cable installation (now using open trenching) and its potential impacts and finally the questions around cable protection.
We have included the full unaltered text below and please see our findings after their response as applicable:
Beach Access
"For complete clarity, throughout construction access to the beach via the existing slipway will be maintained at all times and there will be no disruption to users of the sea/surf for the majority of the construction works undertaken at Saunton Sands. Only when the cable is winched ashore and subsequently installed via cable plough will there need to be management or control of users of the sea/surf to comply with the relevant health and safety legislation. This disruption is likely to be for around 6 hours for each activity and where possible marshals, including lifeguards and safety boats in the water, will be used to ensure some level of access to the sea/surf can be maintained. Where this is not possible, we will work with businesses and other organisations to minimise this disruption. More detail on this in included in Section 5.2 of the Environmental Statement (ES) addendum."
Cabling installation via open trench
"The decision to install the cable via open trench is not a design change. Open trenching was assessed in the documentation submitted last year as the worst case scenario. At that stage the option of installing the cable via a trenchless technique was also considered. However, as a result of ongoing surveys we have provided further information to support our assessment of undertaking the work via open trenching, along with the details of the cable installation with in the nearshore and intertidal. The relevant documents include:
Appendix Y: Outline Cable Landfall Plan: we have provided more detail of the construction methodology in the ES Addendum to support those assessment
Appendix T: Onshore Ground Investigation Interpretative Report: the results of the onshore ground investigation further support the assessment and confirm that the geology and depth of sand is suitable for open cut
Appendix F: Coastal Geomorphology Technical Note: provides further assessment to support the original conclusions in both ES
Appendix U: Cable Burial Risk Assessment: an assessment of the seabed sediment types, where cable protection my be required and the likelihood of exposure
All of these documents will be available when the consultation is launched by North Devon Council. We expect that to be later this week."
Impacts from open trenching
"The further information included within the additional documents support the conclusions of the assessment in Chapter 8: Marine and Coastal Processes (Section 8.5 and 8.6) of the Onshore ES and therefore the conclusions remain unchanged.
During construction the type of cable plough used to install the cable will minimise disturbance. As it installs the cable the excavated material falls back into the cable trench so that the topography of the seabed post-installation will be the same as the topography pre-installation. To confirm this, monitoring prior to cable installation in the intertidal and following backfilling will be undertaken including remedial action if the levels do not match.
During operation and maintenance ‘The only potential impact is the impact on coastal waves due to the physical presence of the offshore infrastructure.’ The wave modelling study we conducted last year conclusively demonstrated that any change would not be noticeable within the natural variation of the waves.
‘There are no other potential impacts on marine and coastal processes of the operation and maintenance of the Onshore Project. This is because the cable will be buried beneath the beach of Saunton Sands, the dunes of Braunton Burrows and the Taw-Torridge Estuary. Hence, coastal processes (wave-driven sediment transport), and coastal geomorphological change (erosion and accretion) will continue uninterrupted by any infrastructure related to the cable.’ "
Cable Protection
"We have not assessed, and do not intend to use, cable protection within the boundary of Bideford to Foreland Point MCZ (i.e., the nearshore and intertidal area at Saunton Sands where the surfing zone is) – see commitments set out in FLO-WHI-REP-0002-10 Chapter 10 Benthic and Intertidal Ecology and Appendix 10.A: MCZ Assessment of the Offshore Environmental Statement which were submitted as part of MLA/2023/00113 in 2023. This is because cable protection is not expected to be required at this section of the offshore cable route (either as part of the initial design, or as remediation in the event of cable exposure).
There are two reasons why:
The intertidal geophysical survey undertaken shows that the depth of sand in this area is up to 7m deep. This shows that there is sufficient depth of sand available to bury the cable to optimal depth in the intertidal area. Therefore, the placement of cable protection in this area has not been identified as being required during construction.
We have also provided more information on the risk of cable exposure during the operation of White Cross Offshore Windfarm in the intertidal and nearshore. The beach rate changes over the 25-year lifetime of White Cross Offshore Windfarm are considered. The north of Saunton Sands beach is dominated by a steady accretionary regime meaning that the sediment supply at the top of the beach will keep pace with sea-level rise into the future and the top of the beach will remain stable. Furthermore, historically, four telecommunications cables also make landfall at this location and have never become exposed. Therefore, it is considered that exposure at landfall is not a realistic worst-case scenario and therefore cable protection in this area has not been identified as being required for remedial action against cable exposure during operation either.
We do anticipate cable protection to be required at other locations across the offshore cable route due to seabed features and cable crossings. The use of cable protection is therefore assessed for some areas, and we expect that the marine licence will allow for the use of cable protection where it is considered and proved to be necessary. It is our understanding that if a marine licence is approved for this project which includes a condition that specifically states that no cable protection is allowed to be used within the MCZ, if the Project identifies a need for it at any stage in the project’s lifetime, then a marine licence variation request will be required. This will require all assessments to be updated (including, but not limited to, effects on marine and coastal processes) so that the worst-case impacts of using cable protection within the nearshore would be thoroughly assessed.
I hope you find this information helpful and that it provides clarity on these key areas of concern. As I mentioned in the email all these additional documents will be available when North Devon Council publish them on the planning portal, which we expect to be later this week. Once they are available on the planning portal we will also upload them to our website Documents - Whitecross (whitecrossoffshorewind.com). "
Conclusions from the NDWSR team thanks to sector experts from experts both in our Local Stewardship Council and external experts in the sector.
We wanted to touch on a few of the points raised in the above correspondence. We have been pleased with the comprehensive and open response from Whitecross, so thank them accordingly.
Monitoring:
We would require more information on pre and post beach level monitoring. How will this be done and will it only be on the intertidal beach (between low and high tide). In which case we need to know how the assurances will cover the offshore area – the surf zone.
Access:
It would be useful to understand how access is planned to be managed to the rest of the beach, will additional pathways be made available etc.?
Trenching:
How will the post installation monitoring be carried out? We look forward to finding their planned methods and any disruption that may cause.
Cable protection:
The above advises that no cable protection will be required within the MCZ (Marine Conservation Zone), where the surf zone falls, however, the option is still there if there is a need to do so. Upon advice we will be speaking to the MMO (Marine Management Organisation) about conditions being added to their license if available.
Cable burial depth:
the supporting evidence here has room for misinterpretation. 1.2m is not very deep, just beyond the depth of change expected throughout the low to mid tide beach (as narrowly evidenced by LiDAR data). We will be looking for a more robust assessment of the past data and for this to be evidenced over an extensive period.
There appears to be an issue is the misinterpretation of data in the recently released Appendix F: Coastal Geomorphology Technical Note. The Whitecross analysis does not identify that the dunes in the cable route (north end of Saunton) area have receded over the 2006-2020 period (by around 15-20m) as evidenced by their presented Figure 1.7. While the beach elevation across the beach may be stable, the landward retreat of the beach and dune system can expose cable within the seaward edge of the dune system if not deep enough. We will be requesting clarity on the burial depths across the dune system relative to mean sea level to provide assurance it will not be exposed.
Cable resurfacing:
This is obviously a very unlikely scenario, but we will be requesting that we are informed and involved if this does occur and find out what the remedial actions would be and who is accountable.
We will keep you updated on this ever-moving matter but would also like to ensure our community knows we are absolutely in support of a move to renewable energy for the future and we will always be led by the facts as they are presented.
If you have any further questions, please contact us directly.
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