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The Place of the Rochdale Envelope Approach in Offshore Renewable Energy

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The Place of the Rochdale Envelope Approach in Offshore Renewable Energy ORE Open Research Exeter TITLE The place of the Rochdale envelope approach in offshore renewable energy AUTHORS Caine, CA JOURNAL Environmental Law Review DEPOSITED IN ORE 11 June 2018 This version available at http://hdl.handle.net/10871/33137 COPYRIGHT AND REUSE Open Research Exeter makes this work available in accordance with publisher policies. A NOTE ON VERSIONS The version presented here may differ from the published version. If citing, you are advised to consult the published version for pagination, volume/issue and date of publication THE PLACE OF THE ROCHDALE ENVELOPE APPROACH IN OFFSHORE RENEWABLE ENERGY With ever-increasing pressure to produce low carbon energy, the offshore renewables industry is growing at a rapid rate. However, with the currently lengthy process from pre-application to obtaining development consent in England, it can take a number of years from securing a Crown Estate lease to obtaining development consent. During this time, the offshore renewables industry is capable of making significant improvements to technology, producing more efficient and larger models. In order to accommodate for emerging new technology within pre- existing offshore renewable development consent applications, a planning approach conceived by case law – the Rochdale envelope approach – has been transplanted into the planning process for offshore renewables allowing developers to describe their project using general parameters that cater for uncertainties at the time of application. However, with little official guidance, developers have been left to advance the approach in such a way that suits their needs. This article will outline the problems of the current application of the Rochdale envelope approach, and will argue that, if left unchanged, these problems will significantly impede the applications of future developers wishing to construct. The article proposes recommendations to guarantee further development of the offshore renewables industry with fewer regulatory impediments. Keywords: Rochdale Envelope; Offshore Wind Energy; EIA; Climate Change Introduction Over the past couple of decades, the renewable energy industry has experienced seismic growth and development, spurred on and incentivised by policymakers who are bound by international and European agreements all baying for a reduction in carbon emissions.1 As financial resources fuel the renewables industry, technological understanding has improved, allowing for more efficient energy generation. This rapid growth in technology is particularly stark in the case of offshore wind energy which has seen turbines more than double in size over a period of the past nine years.2 Unfortunately, as offshore wind developments grow larger, the planning 1 The following European legislation and communication documents demonstrate strong support for the development of renewables within the European Union: ‘A strong European industrial base backing renewables is essential to support the clean energy transition’ (European Commission, 11 January 2018) <https://ec.europa.eu/info/news/strong-european- industrial-base-backing-renewables-essential-support-clean-energy-transition-2018-jan- 11_en> accessed 29 March 2018; Council Directive 2009/28/EC (OJ L 140/16 23.4.09) on the promotion of the use of energy from renewable sources and amending and subsequently repealing Directives 2001/77/EC and 2003/30/EC; Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions (COM 2014 (15) final) A policy framework for climate and energy in the period from 2020 to 2030. 2 Jillian Ambrose, ‘World’s largest wind turbines may double in size before 2024’ (The Telegraph, 17 May 2017) <http://www.telegraph.co.uk/business/2017/05/16/worlds-largest- wind-turbines-may-double-size-2024/> accessed 29 March 2018. and environmental impact assessment (EIA) documents grow longer.3 Consequently, it can take a number of years for a developer of a large scale offshore wind farm in England to work through the data gathering and pre-application stages, through to obtaining development consent.4 During the time it takes for a developer to obtain this permission, the technology in the industry has continued marching on to create more efficient models – models that will be out of the developer’s reach unless they have included them in their original application for permission. In order to accommodate for emerging new technologies within pre-existing offshore wind development plans, a planning approach conceived by case law - the Rochdale envelope approach – has been transplanted into the planning process for offshore renewables allowing developers to describe their project using general parameters that cater for uncertainties at the time of application. The Rochdale envelope approach has been accepted by the English courts as meeting the EIA standards required by the European Union, however, in the twenty-five years after its conception, it has been left to develop under little guidance or scrutiny. Only diminutive guidance has been offered by the then Infrastructure Planning Commission (now Planning Inspectorate) in the UK,5 leaving developers free to advance the approach to suit their needs. This problem has been noticed within legal scholarship, with commentators suggesting that the application of this approach requires further attention and investigation.6 This article will focus on analysing the problems of the current application of the approach in the offshore renewables industry. The article will advocate that if left unchanged, these problems will continue to grow to a point where future proposed offshore renewables may not be able to obtain consent due to inaccurate predictions made by developers 3 To illustrate the size of these documents, the East Anglia ONE offshore wind farm’s environmental statement consisted of 32 chapters which were distributed over 6 volumes of information. These chapters can be individually viewed at the following website: ‘East Anglia ONE Offshore Windfarm’ (The Planning Inspectorate) <https://infrastructure.planninginspectorate.gov.uk/projects/eastern/east-anglia-one-offshore- windfarm/?ipcsection=docs&stage=app&filter1=Environmental+Statement> accessed 29 March 2018. 4 For example, in the case of East Anglia ONE offshore wind farm it took five years from obtaining the site lease from the Crown Estate for the developers to prepare and submit their application, and ultimately obtain consent to develop. 5 ‘Using the “Rochdale Envelope”’ (Infrastructure Planning Commission, February 2011) <https://infrastructure.planninginspectorate.gov.uk/wp-content/uploads/2011/02/Advice-note- 9.-Rochdale-envelope-web.pdf> accessed 29 March 2018. 6 Some of the existing scholarship in this area recognises the benefits of the Rochdale Envelope approach and argues that it provides a much-needed source of flexibility for developers when compiling their applications: G. Plant, ‘Offshore Renewable Energy Development in the British Islands: Legal and Political Risk’ (2013) 4 Renewable Energy Law & Policy Review 189; G. Wright, ‘Strengthening the role of science in marine governance through environmental impact assessment: a case study of the marine renewable energy industry’ (2014) 99 Ocean & Coastal Management 23; J.A. Voormolen, H.M. Junginger, W.G.J.H.M. van Sark, ‘Unravelling historical cost developments of offshore wind energy in Europe’ (2016) 88 Energy Policy 435. The following scholarship provides a more in-depth discussion of the problems associated with the use of the approach amongst other approaches used in the process, however the latter asserts that further analysis of the use of the approach is needed: J. Lonsdale et al., ‘The Amended European Environmental Impact Assessment Directive: UK marine experience and recommendations’ (2017) 148 Ocean & Coastal Management 131; G. Wright et al., ‘Establishing a legal research agenda for ocean energy’ (2016) 63 Marine Policy 126. who have come before them. To combat this, recommendations have been made to ensure that the growing problems associated with the use of the Rochdale envelope approach are not carried forward as the industry develops further. This article will first introduce case law that conceived the Rochdale envelope approach, and illustrate how this approach has developed from the early millennium to the present day. This will then be followed by an analysis of the problems caused by the current use of the approach. These problems are threefold, namely that sparse official guidance has been provided meaning that developers remain uncertain as to where the boundaries of an appropriate Rochdale envelope lie. This then results in the problem of developers submitting wide and unrealistic envelopes which hinder the ability of stakeholders and the consenting authority to comment on the impact that the development will have on sensitive species. Finally, the problem of unrealistic applications putting unnecessary time and financial pressure on stakeholder engagement will be outlined. The article will conclude by making recommendations to ensure that these problems are avoided going forward, ultimately recommending that a report should be commissioned by the Planning Inspectorate to determine what an ‘appropriate use’ of the Rochdale envelope approach is regarded to be in the offshore renewables industry. The results of this report should then inform the following two recommendations from this research that the guidance provided to developers is
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