Briefing Doc: NEPPC to challenge exclusion of North-South interconnector on grounds of discrimination, misrepresentation of the facts and a dereliction of public consultation duties

October 8, 2014

Briefing Document 

 European Commission needs to examine Government and EirGrid practices

Download this Briefing Document in Word Format: Briefing document ‘discrimination’ PR 06October 2014

BACKGROUND

An Bord Pleanála has designated the North-South interconnector project as strategic infrastructure development, and so it requires an Environmental Impact Statement (EIS) to be generated. One of the stipulations of an EIS is that technology alternatives to using 400 kv extra high voltage overhead lines and massive pylons be thoroughly and objectively examined.

For the last seven years NEPPC has contended that the technology alternative of undergrounding is not only technically feasible, but is less costly than pylons in the long run and does not have the same damaging effects on the environment, tourism, farming or human and animal health.

EirGrid has arrogantly refused to seriously analyse an underground cable option for the North-South interconnector, stating from the outset that it was not technically feasible or reliable and would be cost prohibitive.

The issue of comparative costs of overhead lines and underground cables is key factor in deciding which technology should be considered. For this reason, cost and overall value analyses should be performed in the most professional, detailed and objective manner possible. NEPPC has consistently been calling for three actions in this regard:

  1. The identification of a specific underground cabling route on the basis of best commercial, environmental and public acceptance suitability.

 

  1. An objective analysis of the scale of the project and the power capacity realistically required.

 

  1. A comprehensive cost-benefit analysis, encompassing the full range of costs and benefits, including capital costs, operating or lifecycle costs, and impact costs such as land and property devaluation, agriculture, landscape, environment, tourism and project delays.

 

None of the above three reasonable recommendations has ever been seriously examined by EirGrid.

North-South Interconnector Underground Route – Status

EirGrid itself has refused to carry out a specific underground route identification and cost-benefit analysis for the North-South interconnector, despite this being the first major 400kv project in its €3.2 Billion ‘Grid 25’ strategic infrastructure roll-out. Instead, it has relied on quoting theoretical costs from desk top studies and on a fundamentally flawed study, conducted by its partner consultancy firm PB Power.

The study, which was devoid of any terms of reference, was fundamentally flawed in two key areas:

  1. No objective attempt was made to assess, identify and select a relevant underground route for analysis. Instead, a half baked exercise was performed of drawing straight lines across agricultural land alongside the selected overhead lines’ route and carrying out ‘windscreen’ surveys.

 

  1.  The failure to select a representative route rendered the costing analyses in the study to be meaningless. Furthermore, the study stated quite clearly that it focused solely on the costs elements (usually the worst-case scenarios) rather than a proper cost-benefit analysis.

 

Government dismissal of North-South interconnector due process

  1. On 28th January 2014 Minister Rabbitte announced the establishment of an Independent expert Panel (IEP) to oversee the analysis of specific undergrounding options for Grid West (GW) and Grid Link (GL) projects. But the North-South project was purposely excluded.

 

  1. On 7th May 2014 the IEP stated that “whilst the N-S project is not covered by the Government’s decision” the IEP would at least provide an opinion on ”the compatibilities on the methodologies to be employed on GW and GL, with what has already been done for the N-S interconnector” . This was basically a smokescreen to cover the fact that the N-S interconnector was being deprived of a proper analysis.

 

  1. On 1st July 2014 the IEP, after a review of submissions from EirGrid, made the sweeping generalisation that “what has already been done on the N-S project is compatible with the methodologies now being employed on the GW and GL projects”

 

In light of recent activities by EirGrid NEPPC will be challenging EirGrid, the IEP and the Government on the unacceptable discrimination against the North-South interconnector project combined with an inequitable and biased public consultation process.

 

 Recent contradictions by EirGrid on Undergrounding:

A number of recent actions and statements by EirGrid demolish the credibility and bona fides of the company in relation to its responsibilities concerning the North-South interconnector project. Specifically:

  1. The February 2009 PB Power study is the flagship report that EirGrid uses to defend its stance that it has indeed conducted an underground routeing and cost analysis for the North-South interconnector. The ‘Strategic Routeing Criteria’ section of this study (7.3.2, page 69), however, rules out a route along rural roads, and instead seeks to place the route through agricultural areas and recommends the construction of a 20-22 metre swathe which would be as wide as a four lane dual carriageway and would require 390,000 tonnes of hardcore (Fig 1).

Fig. 1

  1. This routeing recommendation was made at the exact same time that PB Power was overseeing the East-west interconnector project for EirGrid, which was planning the placement of a 400kv line along public roads in Wales and from Rush to Woodlands in Ireland.

 

  1. The PB Power report was updated as recently as July 2013, with no changes to the routeing proposal, despite the East-West interconnector being successfully installed along public roads and operational at this stage.

 

  1. As recently as September 2013, EirGrid (Appendix 1) was proposing to Fine Gael that the only North-South underground route option is one across land: “The only practicable option for implementing your suggestion would be to carry out an underground cable survey of the route identified for the overhead line. As I see it this would involve ‘in-field’ surveys by a specialist cable surveyor. In addition surveys by an ecologist, an archaeologist, agronomist and a hydrologist would also be recommended as these are the specialists who would have the greatest concern about the installation of such an underground cable across farmland and through the countryside’ (Deborah Meghen, Eirgrid Manager, HV transmission projects)

 

  1. EirGrid’s underground route analysis for the North-South interconnector is completely at odds with its current underground analysis of the Grid West project.  The Eirgrid project manager for Grid West, in a press statement on 11th July, 2014 (Appendix 2), in direct contradiction to its actions on the North-South interconnector, highlights the reasons for selecting a route along public roads:  ‘why we did not consider a cross-country underground option, one that did not follow the public roads…  “We clarified that it is preferable to route underground high voltage cables along public roads to allow ease of access for monitoring and maintenance of the cable. A cross-country cable route would result in significant construction costs in addition to increased environmental impact. By constructing the cable in the existing public roads, access would be automatically provided.

 

In relation to the roads selected for the underground option, the project team considered a total of twenty-seven road options in conjunction with all the local authorities, relevant agencies and the NRA. These effectively looked at all national, regional and local roads and the selected route represented the best option based on a range of criteria including the length of route, impact of the roads upgrade programme on the security of the cable and the impact on the public during construction”.

In July 2014 EirGrid has produced a seventy page ‘Preliminary Evaluation Report’ (http://www.eirgridprojects.com/media/6424_UG_Routes_Options_Prelim_Evaluation_Report_July%202014.pdf)  on undergrounding Grid West. It highlights that a total of thirty one possible underground cable routes were identified, including four partially submarine routes. The underground route itself, which would also accommodate two communications cables would be only 1.1 metres wide and 1.35 metres deep. 

 

  1. The difference in public consultation and engagement on undergrounding between the North-South interconnector project and that planned for Grid West and Grid Link could not be more extreme – see Table 1below. For instance, currently with Grid West EirGrid has consulted with local authorities in Mayo, Roscommon and Galway, as well as the National Roads Authority and other relevant agencies, identified a number of underground options along public roads, is eliciting feedback, producing a landowner information brochure on undergrounding options

(http://www.eirgridprojects.com/projects/gridwest/projectactivity/) and producing a report for public consultation and engagement. In due course EirGrid will send a letter and detailed map to relevant landowners. None of this has been done for the North-South interconnector, despite it being the oldest project (7 years) and despite these requests being made formally at the planning hearing in June 2010, prior to EirGrid’s withdrawal of the project from the oral hearing.

 

 

 

 

Table 1: Process and public engagement comparison of 400kv ‘Grid 25’ projects

 Undergrounding Criteria Plans

East-West    400kV

Grid-Link     400kV

Grid West 400kV

North-South 400kV

Identify route alongside existing public roads

YES

YES

YES

NO

Select emerging preferred route along public roads

YES

YES

YES

NO

Feedback period from public

YES

YES

YES

NO

Liaison with local authorities

YES

YES

YES

NO

Liaison with NRA

YES

YES

YES

NO

Liaison with other relevant agencies

YES

YES

YES

NO

Landowner information brochure on underground route option

YES

YES

YES

NO

Public consultation process on underground route option

YES

YES

YES

NO

Letter and maps to landowners of underground route option

YES

YES

YES

NO

Route chosen with lowest environmental impact

YES

YES

YES

NO

Recommended use of HVDC cable technology

YES

YES

YES

NO

 

The above facts highlight the following:

  • The North-South interconnector project is being blatantly discriminated against by Eirgrid and by the Government. The undergrounding analysis currently underway for Grid West and Grid Link has never been afforded to the North-South interconnector project.

 

  • EirGrid has wilfully misrepresented the facts regarding options and costs for undergrounding the North-South interconnector project. It has treated the public with contempt in making glaring contradictions to its own previous statements on the subject of undergrounding.

 

 

  • EirGrid has attempted to mislead NEPPC and  by extension, the people of the North-East, with patently disingenuous proposals, unsubstantiated claims on project need and costs and misleading public statements to the media.

 

 

NEPPC is calling for the following actions:

  1. That the newly appointed Minister Alex White  reverses the decision of former Minister Rabbitte to exclude the North-South interconnector from the Independent Expert Panel(IEP) review process.

 

  1. That the IEP requests and ensures an independent analysis of undergrounding the North-South interconnector, thereby allowing a proper comparison with the overhead line planned by EirGrid.

 

  1. That the Government ensures proper public consultation and engagement, as required by the latest regulations related to Projects of Common Interest (PCI).
  2. That Opposition party  elected representatives in the North-East table these requests as motions in the Oireachtas

 

  1. That our elected councillors in Meath, Cavan and Monaghan collectively request EirGrid to work with the local authorities to identify appropriate underground route options along public roads in these counties.

 

 

  1. That our recently elected opposition party MEP’s support our case to the European Commission on the North-South interconnector regarding discrimination, misrepresentation of the facts and dereliction of public consultation duties by EirGrid and by the Government.

 

“What has happened here is unethical and unacceptable, stated Aimée Treacy, chairperson of NEPPC. The exclusion of the North-South interconnector by the Government from a proper undergrounding analysis is a cynical exercise in regionalising the issue and in alienating the communities in the North-East. It is a stunt which will backfire on two fronts: it will only serve to strengthen the resolve of the affected communities in the North-East and it will bolster the absolute determination of more than 95 per cent of the landowners in the area to bar their land against EirGrid, no matter what happens. What remains in tatters, however, is the track record of truly abysmal representation of the communities of the North-East by our Coalition representatives”. Why do our Government elected representatives continue to stand idly by and do nothing to reverse the decision on the exclusion of the North-South interconnector project?

NEPPC has just learned that EirGrid intend to resubmit for planning in the next month. This demonstrates that as far as EirGrid is concerned it is confident that it will obtain an approval without the need for due process.”

 

 

 

North East Pylon Pressure Campaign Limited

087- 680 36 66         pjboreilly@eircom.net

Appendix 1

From:<deborah.meghen@eirgrid.com>
Date:Fri, Sep20, 2013 at 2:52 PM
Subject: North South 400kV Interconnector: EirGrid’s response to UG proposal
To:johnvfarrelly@gmail.com,helen.mcentee@oireachtas.ie
Cc: Aidan.Geoghegan@eirgrid.com

Hi John

I refer to our meeting with yourself and Deputy Helen McEntee TD in EirGrid’s offices on 23rd August 2013 to discuss EirGrid’s proposals for implementing the North South 400kV Interconnection Development using 400kV overhead line in County Meath. During the course of the meeting you suggested that if EirGrid would agree to carrying out a survey of a route for underground cables to the same level of detail as that being carried out for the proposed overhead line that this would address the claims by some landowners that EirGrid was not giving adequate consideration to the underground cable alternative.

I reminded you that we have identified a potential route for underground cable (see the 2009 PB Power report) and that this was done for the purposes of developing a well informed cost estimate for underground cable for comparison with an overhead line. This analysis is in fact more detailed than that done for the overhead line, which is very high level, based on a simple cost per km for 140 km.

While the underground cable route identified by PB Power is different from our preferred route for the overhead line the two routes are sufficiently similar for me to be able to say with confidence that the same landscape types, rivers and roads will be traversed. Surveying the overhead line route for an underground cable would not therefore bring any additional information or accuracy to the existing underground cable estimate as the same rates would still apply. The PB Power cost estimate was updated as recently as April 2013. In that most recent update PB Power concluded that undergrounding using AC technology would cost €742 million more than EirGrid’s proposal to use 400kV overhead line while undergrounding using DC technology would cost €674 million more.

During the meeting I also said that, not surprisingly, the PB Power cable route would involve a very different group of landowners to that impacted by our proposed overhead line. To carry out ‘in-field’ surveys along this route now would cause un-necessary concern and annoyance for this as yet unidentified group of landowners.

On the basis of this we agreed that the only practicable option for implementing your suggestion would be to carry out an underground cable survey of the route identified for the overhead line. As I see it this would involve ‘in-field’ surveys by a specialist cable surveyor. In addition surveys by an ecologist, an archaeologist, agronomist and a hydrologist would also be recommended as these are the specialists who would have the greatest concern about the installation of such an underground cable across farmland and through the countryside.

The information obtained by surveying the overhead line route for an underground cable could then be used as an input into our comparative environmental assessment of installing underground cable or overhead line along the route of the proposed overhead line. The study will be useful in the event of a stakeholder requesting that we assess the impact of undergrounding a short section of the route (often referred to as partial undergrounding).

Therefore we are happy for you to present your proposal to NEPP under the clear understanding that this is not an attempt to gain access by EirGrid but rather an initiative by yourself and Helen acting in the interests of the landowners. If it helps, we would have no objection to a member of NEPP accompanying the survey teams.

Regards

Deborah Meghen, Manager, HV Transmission Projects

 

 

Appendix 2

 

EirGrid’s Grid West project concludes successful round of open days

~ Feedback will form part of analysis on both underground and overhead route options to be reviewed by Independent Expert Panel before the project progresses ~

11 July 2014 -The Grid West project is EirGrid’s plan to develop a new capacity power connection, linking north Mayo to a strong point on the national grid. In June EirGrid announced details of an emerging preferred underground option (underground option) for the Grid West project from north Mayo to Flagford, Co. Roscommon. The Grid West team have now completed a series of five open days, from 7th-11th July, to present the work done to date on the underground option and on proposed localised changes to the overhead route corridor.

The Grid West project manager Sean Meagher said: “This is the fifth round of open days we have held in the region and again we’ve been very pleased with the level of engagement from the public. We received useful feedback on the work we have been doing on developing an underground option as well as proposed changes to the overhead route corridor at the two end points. Among the issues raised by visitors was why we did not consider a cross-country underground option, one that did not follow the public roads, and why particular roads which may be due for upgrade, are not being utilised.”

“We clarified that it is preferable to route underground high voltage cables along public roads to allow ease of access for monitoring and maintenance of the cable. A cross-country cable route would result in significant construction costs in addition to increased environmental impact. By constructing the cable in the existing public roads, access would be automatically provided.

“In relation to the roads selected for the underground option, the project team considered a total of twenty-seven road options in conjunction with all the local authorities, relevant agencies and the NRA. These effectively looked at all national, regional and local roads and the selected route represented the best option based on a range of criteria including the length of route, impact of the roads upgrade programme on the security of the cable and the impact on the public during construction.

“The selected route is the one considered most preferable on the balance of these criteria and the project team will now continue work on this proposed option with feedback received from this round of open days considered as part of this ongoing work.”

EirGrid’s comprehensive analysis of the underground and overhead options will later this year be reviewed by the Independent Expert Panel appointed by the Minister for Communications, Energy and Natural Resources to provide reassurance to the public that all options are being looked at in a fair, objective and comparable way.

Concluding Sean Meagher, Project Manager said: “In the coming weeks, we will be contacting landowners on both the underground and overhead line route options with a view to progressing EirGrid’s analysis of both routes in line with the terms of reference set by the Panel. We hope to present our analysis to the panel later this year, and they have indicated that they hope to be in a position to provide an opinion on this analysis in January 2015. Following this a further round of public consultation will take place early next year.”

ENDS

 

 

 

 

 

 

 

 

 

 

 

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