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Wraxall & Failand Parish Council
Attn. Mark L Winfield Principal Consultant Energy Strategic Consulting Parsons Brinckerhoff Westbrook Mills Godalming Surrey GU7 2AZ
31st October 2011
Dear Sirs
Consultation Response ‐ The Department of Energy and Climate Change, DECC Thank you for inviting us to respond to the consultation. We respond as Wraxall & Failand Parish Council and also on behalf of a number of Parish Councils and campaign groups along the Hinkley to Seabank route.
Our documents, 5th Jan (Report), 21st Jan (Appendix) and 11th Aug (Addendum), (2010), were
submitted to National Grid and IET/KEMA, and are attached for your convenience.
Our report does not align with National Grid's strategic optioneering report, (2011). We believe
our report represents the best current understanding of the financial, legal and political position
and invite you to examine it and consider its implications.
We ask you to meet with us in order to clarify details.
Yours sincerely,
Chris Ambrose CEng Dr. Hugh Pratt
Wraxall and Failand Parish Council
Cc: SoS for Energy Chris Hune MP; Dr. Liam Fox MP; IPC, OFGEM; Local Authorities; CPRE; Campaign
Groups.
Mrs F Shattock Clerk Overmyst Tower House Lane Wraxall North Somerset BS48 1JX Tel: 01275 852112
DECC Consultation Report
Commissioned by Wraxall and Failand Parish Council
on
Hinkley Point C Connection Project
The National Grid’s proposals for the erection of 400KV transmission lines and associated pylons
THE
AMBROSE & PRATT REPORT
Report produced by : Dr. Hugh Pratt
Chris Ambrose CEng November 2011
DECC Consultation Report of 31st October 2011 2 I Page
Executive Summary This report has been produced in response to the invitation from Parsons Brinkerhoff to provide our views on the matter of undergrounding 400KV Transmission lines. The report outlines our contention that the costs for undergrounding could be lower than presently stated in National Grid's Strategic Optioneering Report, (2011). National Grid is constrained by regulation and legislation, and, despite references to the environment and visual impact, the weighting given to these aspects is arbitrary. "Lowest first cost" necessarily must drive National Grid decisions as they are in a monopoly position. National Grid is not known as a research‐led organisation or for creating leading edge technological innovation. When required to consider 'whole life costs' National Grid includes maintenance, operation and now transmission losses. Unfortunately no consideration is given to other whole life costs. These excluded whole life costs should form part of the required Political policy and economic decisions, as the lowest first cost advantage is far outweighed by the longer term economic damage and destruction to the UK's countryside. We are in no doubt that, in any cost benefit analysis, the extended whole life cost will demonstrate the balance in favour of undergrounding the new transmission lines. It will therefore be necessary to provide evidence to support Government policy and decision making. Others are better placed to provide this information, and, If not already done so, we would recommend seeking advice from Allan Provins, senior consultant with Eftec on the provision of such evidence. We also expect from the evidence provided by various 'willingness to pay' surveys, that should £7.00 per year be added to each domestic electricity bill to underground all new transmission lines then this would be acceptable to the majority. It should also be noted that this cost would be more than offset by the protection afforded the Countryside and the consequent retention of the value of local amenities. These natural amenities, together with commercial and retail businesses, maximise the benefit of tourism. Their protection, more pertinently, may prevent a potential impact on the NHS due to related illnesses. We recommend for further reading the London Economics report, (2011) prepared for OFGEM, and any appropriate follow up.
DECC Consultation Report of 31st October 2011 3 I Page
Overhead lines 57km Build Cost £613m Life Cost £138m Total £751m Cost/km £13.17m From National Grid(2011)
Gas Insulated Lines 57km Build Cost, 6 tubes £687m Life Cost £231m Total £918m Cost/km £15.6m From Pratt Ambrose(2011)
DECC Consultation Report of 31st October 2011 3 I Page
Introduction
Unfortunately, due to many of the documents being too "wordy", the assumptions are not readily
obvious, and therefore it is hard to make an informed judgement.
Consultation matter ‐ Willingness to Pay.
Consultation 1.1 EFTEC [2006], Scottish and Southern [2008], Competition Commission
[2010] and Brunswick [2011] provided well balanced reports demonstrating
a general willingness to pay for undergrounding. London Economic (2011),
prepared for OFGEM, reflects on the various studies and how to apply the
results of the willingness to pay studies. The report's key conclusion is that
setting a weighted allowance should be used to input to a cost benefit
analysis.
Consultation 1.2 National Grid [2010] confirms that domestic electrical bills would only
increase by £1 per year per £1 billion invested. Therefore:
1.2.2 The £200 billion to provide alternative energy, (Green Renewable),
would therefore add £200 to every domestic electric bill per year.
1.2.3 The £17 billion to provide all the currently planned work would
therefore add £17 to every domestic electric bill per year.
1.2.4 The £7 billion required to underground the currently planned work
would add only £7 to every domestic electric bill per year.
Consultation 1.3 OFGEM [2011] recognises that National Grid Electrical Transmission
Business Plan is not yet adequate for making a decision. This we believe
suggests that the "last responsible moment" for making a decision has not
yet arrived.
Consultation 1.4 Devine‐Wright [2010] & [2011] surveyed people affected by a proposed
pylon route and showed that there were perceived health effects from
overhead pylons. There were also the visual impacts of pylons which serve
to industrialise rural places, disrupt place attachments and incite local
opposition. They also challenge the "NIMBY "assumption and also decision
making under the UK‐IPC mandated public‐consultation strategy. This has
DECC Consultation Report of 31st October 2011 4 I Page
closed down opportunities for community involvement in decision‐making
and exacerbated public mistrust of National Grid.
Consultation matter ‐ Costs
Consultation 1.5 Any informed judgement is clouded by the complexity of the problem and
the planning processes which are different for overhead, undersea and
underground solutions.
Consultation 1.6 The Electricity Safety, Quality and Continuity Regulations [2002] has further
limited the options which are chosen by the definition of an "overhead line"
as being the default design.
1.6.1 A political solution could be to simply amend the definition of an
overhead line in the Act. No further changes would be necessary.
Consultation 1.7 We have sought to provide a holistic costing methodology rather than a
capital cost analysis.
Consultation 1.8 It should be recognised in the political decision, on which option to choose,
that it is necessary to have regard to the following matters omitted in
National Grid's analysis:
1.8.1 Property blight.
1.8.2 Electro‐magnetic illness or perceived stress related illnesses because
of the patient's belief that overhead powerlines are a hazard, or the stress
caused by an inability to sell a blighted property.
1.8.3 The cost to the NHS including for mental or medical care and to GNP
in lost hours, low productivity or absence due to illness outlined above.
1.8.4 A reduction in income for tourism and related industries following a
drop in numbers of tourists.
1.8.5 Reduction in national security, (from overhead lines), due to
accessibility for theft and terrorism, lightning strikes and extreme weather.
1.8.6 Increased security from an underground methodology.
1.8.7 The benefit from a 50% reduction in transmission losses by
undergrounding power lines, (depending on methodology). Power
DECC Consultation Report of 31st October 2011 5 I Page
transmission losses warming the ground are more beneficial to the local
environment than directly dissipated into the atmosphere, (warming the
globe), by overhead power lines.
1.8.8 Siemens ‐ Fox (2011) offer an increase in job opportunities to
manufacturing industry by building GIL tubes in the UK.
1.8.9 The cost benefit of volume production and export opportunities
generating growth and wealth in the UK economy.
Consultation matter ‐ How we got here?
Consultation 1.9 The reader might be wondering at this moment how we have all arrived at
this point in creating a need for a review of costing, (especially when
comparing underground transmission solutions to overhead powerlines).
1.9.1 National Grid (2009) and (2010) [video] announced its intention to
build a 3.6GW feed line from the proposed nuclear power station at Hinkley.
1.9.2 National Grid offered a 1960s methodology for the electrical
transmission.
1.9.3 Wraxall and Failand Parish Council produced a response with
alternative views. (Note: Wraxall and Failand Parish Council have received
no formal critique from National Grid to their response since it was
submitted 22 months ago).
1.9.4 As a result of our reports, there has been an incremental shift by
National Grid from their 1960s comfort zone. National Grid moved from a
position of denying the technology for an undersea solution to an
acknowledgement of their existing undersea cables. They also now admit
having had built two GIL installations. National Grid (2010) & (2011) have
changed the cost ratio of undergrounding powerlines, (from 12 to 17 times
to 3 to 10 times), more expensive than overhead powerlines.
1.9.5 This apparent lack of awareness by National Grid has severely
damaged the credibility of the data which has been generated in their
optioneering reports.
DECC Consultation Report of 31st October 2011 6 I Page
1.9.6 It is sad and misleading, that the latest optioneering report shows
pylons of the wrong size, about 26m , on its front cover, see page 2. This can
be understood from the fact that oaks, measuring from 8m to 12m high,
portray the pylons to almost 26 m rather than the proposed 46m.
1.9.7 Over the period of this consultation there has been a change of
emphasis by National Grid in their intentions:
1.9.7.1 The proposed line from Hinkley to Avonmouth has now been
increased to a strategic line requiring a double circuit for security
and increased power to 6 GW. (This will be discussed in 1.13 below).
1.9.7.2 This change in power and security is reflected in the costings
generated in Table 2.
Consultation 1.10 It is important to recognise that the cost per kilometre of any proposed
connection will not necessarily determine the total cost. In the case of
Hinkley to Avonmouth, pylons will be required to take a less direct route to
avoid built up areas and cannot be placed in the most direct line where
undergrounding can be. In this particular case several miles of transmission
have been saved.
Consultation 1.11 We draw the reader's attention to the costing methodology which is used by
National Grid where the prime supplier has to take the lead role in a turnkey
contract. This therefore results in less competitive pricing for the project
due to the nature of the procurement, particularly the civil works.
1.11.1 Onions [2011] suggests a price of £2m per km to create all civil works
associated with a 4.5m x 3m deep trench. However he draws attention to
interesting points including £0.5m per km for earthworks and leverage from
procurement methods.
Consultation 1.12 We draw the reader's attention to Siemens' email [2010] for the provision of
a complete GIL installation of €6.0m per km, (excluding civil works). This
flows from a cost range of €4.0m per km, in the desert, to €10.0m per km,
for vertical tubes in a Chinese mountain.
Consultation 1.13 We draw the reader's attention to National Grid's requirement for a double
circuit for security which would require three additional overhead cables.
This is to allow for the potential of a lightning strike or mechanical
DECC Consultation Report of 31st October 2011 7 I Page
breakdown taking out the three phases. However the N+1 requirement can
have different methodologies for an underground installation. Firstly
lightning would not damage the underground conductors and it is unlikely
that any mechanical breakdown would simultaneously take out all the
underground conductors. Should one underground conductor fail a design
of 4 conductors, instead of 6, would provide N+1 security.
1.13.1 A guide price for 4 tubes, instead of 3, would be €8.1m per km. This
allows for the extra switchgear to switch the redundant tube used for extra
security. For N +2 security 5 tubes could be used etc.
Consultation 1.14 We draw the reader's attention to the fact that GIL does not need to be
undergrounded in order to work. It could be placed directly on the ground,
raised above it, or buried, see Figure 1. It could be placed in a shallow tray
requiring no net change in materials producing a slightly raised structure,
see Figures 2 & 3. This could become a green highway for the migration of
wildlife, and for increasing tourism and exercise. In this way it would
improve the wealth and the health of the local area which could be directly
contrasted with the proposed overhead powerlines.
Figure 1 Some options for installing GIL
DECC Consultation Report of 31st October 2011 8 I Page
Figure 2 Shallow tray installation of GIL
Figure 3 Sketches of possible installation for GIL
DECC Consultation Report of 31st October 2011 9 I Page
Consultation 1.15 The authors of this report have sought to understand the ground work cost
as supplied by National Grid [2011] Table 3 on page 122.
1.15.1 It requires little extra cost to underground 3 or 6 tubes if they are
0.375m or 0.5m diameter so the trenching cost should be the same, (We
have not priced the duct.)
1.15.2 National Grid's calculations, surprisingly, show a range from £1.35m
to £9.3m per km to underground for the "same" civil works. We have
interpolated National Grid's calculations using Siemens email [2010] price
structure, table 1.
Table 1 – Deduced trenching cost from National Grid's Optioneering Report
Consultation matter ‐ Supporting information GIL
Consultation 1.16 Siemens (2010), Kunze et al. (2007), Bazannery (2000), Siemens letter
(2011) all paint an upbeat picture of GIL technology with a 2011
manufacturing tube capacity of 200km. This, the authors understand, can be
rapidly increased. We suggest National Grid may have "requested" the
Siemens' Statement (2011) to reflect the probability of meeting the 2018
delivery date, for Hinkley, rather than a realistic 2019 date and not to solve a
technological problem.
GIL Type Cost per circuit Tube
National Grid's Deduced National Grid's Deduced
based on current Amp
complete electrical diameter
cost per circuit
civil works for one circuit
cost per double circuit
civil works for a double circuit
rating system 3 tubes 6 tubes £m/km m £m/km £m/km £m/km £m/km 2000A Rated GIL 5.4 0.375 6.75 1.35 13.5 2.7 4000A Rated GIL 5.4 0.375 7.6 2.2 15.2 4.4 5000A Rated GIL 6.75 0.5 11.4 4.65 22.8 9.3
DECC Consultation Report of 31st October 2011 10 I Page
Consultation 1.17 There are some key points to GIL which need re‐ emphasising:
1.17.1 High Reliability – Siemens (2010) claim their GIL technology has
proven its reliability with over 35 years in service without any failure up to
now and demonstrate low transmission losses.
1.17.2 No ageing ‐ The insulation system of GIL shows no ageing
phenomena, neither electrical nor thermal. There is practically no
maintenance needed on the GIL for up to 50 years or more.
1.17.3 Maintenance‐free design ‐ As the technology is a clear‐cut logical
design, coupled with the use of high quality materials, it provides a
practically maintenance‐free product which requires external inspection
only. The GIL can also stay in operation during regular inspection activities.
1.17.4 Old technology ‐ GIL technology has been extensively used since the
1970s.
1.17.5 Footprint ‐ GIL has only a 10th of the spatial footprint of an
overhead power line, and no carbon footprint.
1.17.6 Recyclability ‐ There is no gas replenishment required during a fifty
year life. After which, all the metal components and 99.8% of the gas can be
recycled.
1.17.7 Standard – IEC (2009) reflects a well developed standard and a
mature industry.
Consultation 1.18 We have updated our spreadsheet to read £ per km, to harmonise with
National Grid's Strategic Optioneering Report, (2011), which presents all the
options for consideration, Table 2. Detail costing methodology can be found
in our previous documents.
Consultation 1.19 Figures in National Grid's Strategic Optioneering Report, (2011) pages 20, 22‐
29 and 96‐102 need to be carefully examined for inconsistencies.
Consultation 1.20 These inconsistencies can be put in to context in Table 2. In particular the
comparison of our and National Grid's cost per km.
DECC Consultation Report of 31st October 2011 11 I Page
DECC Consultation Report of 31st October 2011 12 I Page
DECC Consultation Report of 31st October 2011 13 I Page
Consultation 1.21 The transmission losses remain a key part of the lifetime costs of any of the
transmission technologies.
1.21.1 It is important to quantify this using realistic modelling and we are at
a loss to understand National Grid's methodology, pps 108‐ 212, of their
recent Strategic Optioneering report, August 2011.
1.21.2 Step 1 ‐ Power requirements: The report sets out a design of 6 GW
but uses 3.1 GW being further reduced to 1.05GW. (Furthermore the
utilisation factor varies considerably across the globe and in some European
countries approaches 80%).
1.21.3 Step 3 ‐ Voltage: National Grid's convention is to present the
voltage as phase to phase yet the calculations show phase to ground. Clarity
is required as to whether they have designed 400 kV phase to phase, (which
is 230kV phase to neutral, (ground)).
1.21.4 Step 4 ‐ Line length: The report suggests a line length of 60 km but
that does not take account of the number of wires. For instance originally
National Grid suggested 18 lines, now reduced to 12, which would give an
aggregate length of 1080 km or 720 km.
1.21.5 Step 7 ‐ Cost per megawatt hour: The cost at £60 per megawatt
hour does not reflect the cost to the consumer which will dramatically
escalate over the next 40 years, to carry the cost for renewable energy. A
proper price should therefore be factored.
1.21.6 We draw these shortcomings to your notice.
Consultation 1.22 Our recommended methodology, for overhead lines, is based on 120w/m, of
heating loss, as described in our previous report and particularly in Appendix
13.
DECC Consultation Report of 31st October 2011 14 I Page
Consultation matter – Conclusion
Conclusion 1.1 Although undersea conductors provide an attractive solution for the Hinkley
to Avonmouth connection, we conclude that GIL technology is still
demonstrably the most attractive and competitive on cost. It also provides
ease of interconnection and provides the lifestyle which people desire,
recognise and deserve. More importantly GIL will contribute to the
requirements to meet the 2020 targets for global warming and recycling.
Conclusion 1.2 The GIL can be manufactured in the UK and thereby contribute to the
economic growth and wealth creation the country needs.
Consultation matter ‐ Recommendation
Recommendation 1.1 We recommend that GIL should be used for the transmission of
power between Hinckley and Avonmouth and considered for all new
transmission lines.
1.1.1 We are also aware of the embedded lack of public trust in National
Grid, the Government, the Media, and external research organisations. It is
crucial therefore that independent experts should not all be part of, or
contracted to, or working for National Grid.
1.1.2 We also recommend that the different options be examined, by
means of computer modelling and by full size mock ups, in order to
appreciate the extent of the potential for savings both on the civil works,
the N+1 philosophy and the potential for time saving.
DECC Consultation Report of 31st October 2011 15 I Page
Additional references: • Bazannery G 2000. Underground links by gas insulated transmission lines APSCOM 2000 • Brunswick 2011. Attitudes to energy transmission: summary of key findings
http://www.nationalgrid.com/NR/rdonlyres/B6F18C8B‐03CF‐4428‐8103‐2EA91185B81A/48198/AttitudestoEnergyTransmissionJuly2011.pdf Downloaded 29 October 2100
• Competition Commission 2010 Review of stated preference and willingness to pay methods http://www.competition‐commission.org.uk/our_role/analysis/summary_and_report_combined.pdf Downloaded 29 October 2100
• Devine‐Wright P. 2010 Putting pylons into place: a UK case study of public beliefs about the impacts of electricity transmission‐ line‐siting. www.supergen‐networks.org.uk/filebyid/623/file.docx Downloaded 29 October 2010.
• Devine‐Wright P. 2011, Place,emotion and identity: exploring alternatives to the "NIMBY" (not in my backyard) concept BPS seminar, Exeter 5th April 2011 http://blogs.cf.ac.uk/whitmarsh/resource/DevineWright.pdf Downloaded 29 October 2100
• EFTEC (2006) The overview of valuation of visual impacts of transmission price control review (TPCR). EFTEC, 16 Percy St. , London W1T 1TD
• International Electrotechnical Commission. 2009. IEC 62271‐1 ed.1.0 High‐voltage switchgear and control gear – part 204: Rigid high‐voltage, gas‐insulated transmission lines for rated voltages of 72.5kV and above. Geneva: IEC
• Kunze D. et al 2007. Gas‐ insulated transmission lines‐underground power transmission achieving a maximum of operational safety and reliability JICABLE Conference
• London Economics 2011 Review of company surveys on consumers' willingness to pay to reduce the impacts of existing transmission infrastructure on visual amenity in designated landscapes, final report to OFGEM http://www.ofgem.gov.uk/Networks/Trans/PriceControls/RIIO‐T1/ConRes/Documents1/visualamenity.pdf Downloaded 29 October 2100
• National Grid [2009] Hinkley Point C Connection Project Pamphlet • National Grid 2010. [Costs] (Personal communication to Paul Hipwell, 24 September 2010) • National Grid 2010 Video
http://www.save‐our‐valley.co.uk/SOVvideo.html Downloaded 29 October 2010 • OFGEM 2011. [Business plan] (Personal communication to Generators, 24 October 2011) • Onions C 2011. [Costs] (Personal communication to Chris Ambrose, 30 October 2011) • Scottish and Southern 2008. [Willingness to pay] (Personal communication to Laura Nell, 8
September 2008) • Siemens 2011. [GIL system] (Personal communication to Hugh Pratt, 18 January 2011) • Siemens 2010. [Costs] (Personal communication to Hugh Pratt, 30 July 2010) • Siemens Statement 2011. [Costs] (Personal communication Dr. Liam Fox MP, 16 August
2010) • Siemens 2010. Gas‐Insulated transmission lines (GIL)
http://www.energy.siemens.com/hq/en/power‐transmission/gas‐insulated‐transmission‐lines.htm Downloaded 29 October2011
• Siemens to Fox 2011. [Manufacturing] (Personal communication to Dr. L Fox MP, 25 May 2011)
• The Electricity Safety, Quality and Continuity Regulations 2002 No. 2665