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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.


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)


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


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


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.


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


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


Figure 2 Shallow tray installation of GIL

Figure 3 Sketches of possible installation for GIL


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


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.


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.


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.


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