The Offshore Renewable Energy Action Plan & NI’s Road to Net Zero

The Department for the Economy (“DfE”) is progressing the Offshore Renewable Energy Action Plan (the “OREAP”), currently in draft format with public consultation closing on 16^th March 2023. The OREAP details strategic priorities, objectives and actions intended to be undertaken to allow, if practicable, for the successful implementation of 1GW of offshore wind energy by 2030 in Northern Ireland.

Heralded by the DfE as “Northern Ireland’s most ambitious energy infrastructure plan, supplying enough energy to power one million homes with clean and affordable electricity”, the OREAP focuses on collaboration between various public and private stakeholders with an emphasis placed on the economic and societal benefits associated with offshore renewables and the streamlining of planning, consenting and licencing processes to enable the realisation and prioritisation of offshore renewable projects.

This article examines the key areas of the OREAP and considers its potential impact in the context of Northern Ireland’s pursuit to meet its various climate commitments.

Background

As part the UK’s overarching Net Zero Strategy by 2050, the DfE introduced The Energy Strategy and Energy Strategy Action Plan 2022 (“Energy Strategy”) to assist in laying out NI’s route to a low carbon and sustainable future and under which the 1GW of wind by 2030 target was included. The Climate Change (Northern Ireland) Act 2022 further set the benchmark of 80% clean energy by 2030, an increase from the 70% originally committed to under the Energy Strategy.

With these and other various climate commitments in mind, the DfE established the OREAP Steering Group and OREAP Working Groups to identify the main areas of focus to help realise offshore wind development and also to oversee the OREAP’s delivery. The draft OREAP was subsequently published on 22^nd December 2022 and a Statement of Intent published on 16^th January 2023 between the DfE and The Crown Estate, setting out some of their respective roles and responsibilities and the nature of their collaboration related to offshore renewable development.

Key provisions of the OREAP

It should be noted that the OREAP is still in draft format and the provisions and likely timescales listed are ambitions only, and it is difficult to see how they can be achieved without an early return of a working Executive . It has been developed with a flexible approach in mind, allowing for changes to be made to it as and when required. It is not a definitive confirmation that offshore wind energy projects will be in operation by 2030. It does however set out in some detail the key areas and corresponding actions that will need to be explored if wind energy targets are to be met.

The OREAP has five overriding themes. These are the strategic priorities of the OREAP and under each, there are key objectives and specific actions identified that detail how these strategies will be achieved:

1. Sustainability and Co-existence

The OREAP takes a sustainable and considered approach to offshore development. Under OREAP, it is intended that the 2012 Strategic Environmental Assessment and Habitats Regulations Assessment of Offshore Renewable Energy in the Northern Ireland Marine Area will be updated. Renewable energy policy is to be continuously reviewed in light of existing marine and environmental policy to ensure that there are no discrepancies or gaps. There will also be a focus on ensuring that the site locations of any future wind projects are in the most sustainable areas and for the benefit of the local community.

2. Enabling Frameworks

This strategy breaks down some of the key steps and approaches to be taken by the relevant stakeholders to put in place an effective process for offshore development. Planning, licences and consents are to be a key focus of the OREAP to allow for a streamlined approach to obtaining the relevant consents and agreements required for offshore projects. Marine licencing, development consent and generation and transmission licences are all areas to be considered and focused on under the OREAP. A strategy for the decommissioning of offshore projects is also to be put in place.

A Memorandum of Understanding is to be created between the DfE, the Department for Infrastructure (“DfI”) and the Department of Agricultural, Environment and Rural Affairs (“DAERA”) to allow for the prioritisation of consents and application processes related to offshore projects.  This will be key to timely delivery.

3. Electricity Networks

The OREAP recognises the interdependency of NI’s electricity network with any planned offshore projects. As such, a collaborative approach is to be taken with a joint group made up of governmental departments and network providers to be established to ensure that the electricity framework for offshore projects is in place and is utilised effectively. The focus will be on key areas identified including offshore transmission arrangements and grid development matters such as options for offshore connections under existing processes.

4. Economic Growth

The development of offshore wind energy projects will bring with it a requirement for new labour and skills and the possibility of exploiting this for the benefit of the economy and local communities. The OREAP recognises this and aims to put in place an approach that allows NI’s economy to reap the benefits. The actions specified under the OREAP include engaging with schools and universities in order to build up the skills required for such projects, putting in place an awareness campaign to encourage uptake and establishing policy that will aim to ensure that the local economy plays a role in the supply chain of the offshore projects.

5. Legislation and Regulations

Under the OREAP, relevant legislation and regulations are to be reviewed with a focus on ensuring alignment with offshore renewable projects and where appropriate, amendments made to such legislation and regulations specifically with reference to offshore transmission arrangements and the use of low carbon technologies such as green hydrogen.

Accountability under the OREAP

The OREAP provides mechanisms by which the delivery of action points are more likely to be delivered.

Ongoing strategic level monitoring will take place by the DfE with updates provided to the Steering Group and Energy Forum and a report to be published annually. The Steering Group is to also act as a monitoring body throughout the OREAP’s lifespan.

Key takeaways and conclusions

Whilst still very much in its infancy and awaiting the outcome of the public consultation, the OREAP marks a significant step forward for Northern Ireland’s clean energy drive. Overall, the OREAP provides a holistic and considered approach to what is practically required in order for offshore wind energy to be realised in Northern Ireland. It understands that in order to be successful it will require consideration of the many moving parts associated with this difficult task and it will be interesting to see how the OREAP develops and adapts moving forward.  Much depends though on the return of a working Executive and a robust Memorandum of Understanding to address delays in the consenting process.

This article has been produced for general information purposes and further advice should be sought from a professional advisor. For further information about any of the issues raised in this article, please feel free to get in touch with our Planning & Environment team.

This article was co-authored with Trainee Solicitor, Edward Bergin.