EN030002-000746-University of Manchester
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Office of the General Counsel Room 2.003 John Owens Building The University of Manchester Oxford Road Manchester M13 9PL Tel: +44(0)161 275 2770 [email protected] www.manchester.ac.uk 29 April 2016 By Post and EMAIL The Planning Inspectorate 3/18 Eagle Wing Temple Quay House 2 The Square Bristol BS1 6PN [email protected] Dear Sirs PLANNING ACT 2008 APPLICATION FOR AN ORDER GRANTING DEVELOPMENT CONSENT FOR THE KEUPER GAS STORAGE PROJECT (“ORDER”) PLANNING INSPECTORATE REFERENCE NUMBER: EN030002 INTERESTED PARTY REFERENCE NUMBER: 10032024 THE UNIVERSITY OF MANCHESTER Further to the Examining Authority’s Rule 8 letter dated 23 March 2016, please find enclosed: 1. Written Representations of the University of Manchester 2. Annexures to the Written Representations of the University of Manchester 3. Response to the Examining Authority’s Question 10.7. In response to the Examining Authority’s Rule 13 and 16 letter dated 20 April 2016; I can confirm that the University will, subject to further discussions with the Applicant, attend the Issue Specific Hearing on the local environmental impacts and the draft DCO on the 25 May 2016 and the continuation of the Issue Specific Hearing on the local environmental impacts and the draft DCO on the 26 May 2016. Upon attending, the University would wish to speak on the issue of the potential for radio interference arising from the Order and would further reserve the ability to speak on any issue that arises during the course of the meeting that is of relevance to the University or that may otherwise be of assistance to the Examining Authority. If, upon reading the University’s Written Representations, the Examining Authority considers it useful to attend Jodrell Bank Observatory prior to any Issue Specific Hearing (or at any point in the course of the examination) we are very happy to accommodate a visit. Please contact me as early as possible in order that the necessary arrangements can be made. Yours faithfully Julia Wentlandova Solicitor – Estates Office of the General Counsel Keuper Gas Storage Project Planning Inspectorate Reference: EN030002 Written Representation of The University of Manchester Interested Party Reference Number: 10032024 1. Summary 1.1. Radio astronomy provides a unique view of the Universe, revealing material that cannot be detected by telescopes operating at visible or other wavelengths, looking into the most highly obscured parts of galaxies, and routinely producing images at higher resolution than any other telescopes. However, unlike any other type of astronomy, the ‘light pollution’ which affects radio telescopes in the form of radio transmissions and unwanted radio noise, is very powerful and all- pervasive. The future of radio astronomy relies on simultaneously maintaining the continued regulatory protection of key frequency bands, continued protection of radio telescope sites from the build-up of activity which generates radio interference, and continual development of radio astronomy techniques to distinguish between cosmic and terrestrial signals. 1.2. Jodrell Bank Observatory (JBO) is the UK’s primary radio astronomy facility, operated and maintained by the University of Manchester and the UK Science and Technology Facilities Council (STFC). The 76-m Lovell Telescope is still the third largest steerable radio telescope in the world and operates more effectively now than ever before. It is used by hundreds of research astronomers from the UK and around the world, including almost all UK university astrophysics research groups. Jodrell Bank radio telescopes are used as part of international networks which combine signals from all of the largest radio telescopes in Europe and around the world. 1.3. Jodrell Bank carries out world-class research in many of the key science topics of modern astrophysics and also has a vital and well-established role in communicating that science to the general public through the Jodrell Bank Discovery Centre. Its contributions throughout the development of radio astronomy as a technique and a new branch of science are unrivalled in the world. Continued investment in JBO has 2 maintained its world-class status and further major investment is being made now to guarantee its future scientific competitiveness for the next 20 years or more. This combination of an unequalled heritage, world- class science, public engagement and ongoing development underlie the decision to host the headquarters of the International Square Kilometre Array at Jodrell Bank with the full support of UK government. 1.4. National bodies which administer the use of the radio spectrum (Ofcom in the UK) protect key frequency bands for radio astronomers and respect internationally recognised definitions of the levels at which interference into these bands causes harm to radio astronomy. However, the unintentional emission of radio signals by domestic or industrial equipment is not controlled by the spectrum allocation process. 1.5. The future of radio astronomy relies on simultaneously maintaining the continued regulatory protection of key frequency bands and protecting radio telescope sites from the build-up of activity which generates harmful radio interference. 1.6. The proposed Keuper Gas Storage Plant poses a potential risk to JBO operations. By way of illustration, the high power compressor installations alone may generate radio frequency interference above the level deemed harmful to radio astronomy. It is important to note that other elements of the proposed plant may also generate radio frequency interference and as such, the proposals need to be considered as a whole. The appropriate criterion is to demonstrate that the internationally agreed thresholds set out in ITU-R RA.769 are not exceeded. 1.7. The Applicant has not assessed the potential for likely radio frequency emissions to cause harmful interference at JBO. There is no analysis of the effect of the equipment likely to be used on radio telescopes, despite the national and international importance of the JBO and the location of proposals partly within or on the periphery of the Jodrell Bank Radio Telescope Consultation Zone in local development plan documents. 3 1.8. In the absence of further information on the likely radio emissions from the proposals, JBO has used the maximum radiated power recommended for smaller systems under a British Standard as a benchmark. Using this benchmark, JBO estimates that in the absence of mitigation measures, there is the potential for proposed electrical equipment to produce harmful interference to the Jodrell Bank radio telescope which exceeds the internationally agreed threshold. 1.9. Further assessment work is required to assess the effects of these proposals. It is essential that before this proposal is permitted the Applicant is able to quantify the likely level of radio frequency emission in the key frequency bands used by JBO and demonstrate either that the emissions will not be harmful to the operation of JBO or that sufficient radio frequency shielding is installed by way of mitigation and maintained throughout the operation of the facility, to ensure that the efficient operation of the Jodrell Bank radio telescopes is not impaired. 2. Introduction 2.1. These Written Representations are prepared on behalf of the University of Manchester (“the University”) in response to Keuper Gas Storage Limited’s (“the Applicant”) application for an order granting development consent for the Keuper Gas Storage Project (“Proposed Order”). 2.2. They have been prepared primarily by Professor Simon Garrington whose professional details are set out at Annex 1. 2.3. The University is concerned about the potential impact that the Proposed Order will have on the work undertaken at the University’s Jodrell Bank Observatory (“JBO”). Pictures of JBO appear at Annex 2. 4 3. What is radio astronomy and why does interference matter? 3.1. Radio astronomy is a branch of astronomy which involves the study of radio energy or radio waves emitted by objects in space. 3.2. Radio waves are part of the electromagnetic spectrum. Visible light is one form of electromagnetic radiation; other forms are radio waves, infra- red, X-rays and Gamma-rays. These different forms of “light” have different wavelengths, ranging from several metres for radio waves to less than one billionth of a millimetre for gamma rays. 3.3. Any object, including an object in space, will generally radiate energy across some part of the electromagnetic spectrum, with a broad peak in the emission at a particular wavelength. At longer wavelengths (such as radio waves), the energy emitted is much less. The Sun has a peak emission in the optical part of the spectrum, to which our eyes are adapted to work. At radio wavelengths, approximately one million times longer than optical wavelengths, the Sun (and indeed any other normal star) is very faint: much more than a billion times fainter at radio than optical frequencies. By way of illustration, the typical signals which provide mobile phone coverage are more than 10 million times stronger than the radio emission from the sun, which is by far the brightest individual source of radio emission in the sky. 3.4. Astronomers study objects in space, including stars, galaxies and the gas between them, using instruments which operate at various wavelengths across the electromagnetic spectrum. The atmosphere blocks our view of space at most wavelengths: the only two ‘windows’ which allow observations from the Earth through our atmosphere are at visible/near infra-red and radio wavelengths. However, when viewed at radio wavelengths, the sky appears very different to the view provided by our 5 eyes or large optical telescopes. Radio astronomy allows the detection of phenomena in space which cannot be observed at any other wavelength, and the discoveries of radio astronomers in the second half of the 20th century changes our view of the heavens. The most common element of the Universe, hydrogen, can only be observed in its neutral state at radio wavelengths.