Consultation response – area division of Utsira Nord for offshore renewable energy production

Vårgrønn refers to the Ministry of Petroleum and Energy's consultation of 9 February 2022 on the division of areas opened for offshore wind. This response is a joint answer on behalf of Equinor and Vårgrønn.

The division of areas for Utsira Nord should fulfill the goal of developing the industry within floating offshore wind in Norway. Such industrial development requires that we move from technology development and testing to industrialization. This is crucial to achieving the necessary cost reductions to create a viable industry within floating offshore wind.

Scale and volume, together with further development of technology and logistics, are the most important elements for achieving industrialization and cost reductions in this area. Utsira Nord should therefore be divided into a smaller number of large projects in order to achieve scale and volume that promotes industrialization and cost reductions, and which thus provides a fundament for Norwegian industrial development in floating offshore wind. We primarily recommend that Utsira Nord will be divided into three large projects, as further described below.

Our recommendation is to further distinguish between the development of new and immature technology and the further development of more proven and mature technology suitable for industrialisation. New innovative technology, including significantly more area-efficient solutions, will require extensive and time-consuming testing and qualification before it can be used in a full-scale development and production. Development and improvement of technology is crucial for the industrialization of offshore wind, but new and immature technology should be tested and developed on a smaller scale (few units) and preferably in dedicated test centers and not as part of an industrial development of wind power.

Large industrialization projects and smaller technology development projects will also have very different drivers, in which can make a potential coordinated grid solution difficult if this is chosen. In our opinion, it is therefore not appropriate to make a division that facilitates both large industrialization projects and smaller technology development projects for Utsira Nord.

In addition to this, we have the following input on the Ministry's proposed division of Utsira Nord:

• For Utsira Nord, we agree with the eastern safety zone based on reasoning for ship traffic, and have this as a fundament in our proposal for area division. For new area divisions, the need for safety zones should be assessed separately based on area-specific risk considerations.
• The proposed Field West includes an area where the gas pipeline from Johan Sverdrup has been installed. To ensure the integrity of the gas pipeline, there will be restrictions on both anchoring and cable laying in this area and it will most likely be necessary to establish a buffer zone around the pipeline. In our proposals for division of areas, we have assumed a buffer zone of at least 100 m on each side of the pipeline where anchors should not be installed or anchor lines should not cross. To reduce the extent of cable and anchor crossings, we recommend that the pipeline remains in a buffer zone.
• The size of the zone around the pipeline and other restrictions must be clarified in more detail with the Johan Sverdrup licence.
• Calculations of wind shadow show that the buffer zone of 5 km can be reduced to around 3 km without significant losses of production. This assessment is based on the fact that the anchor must be placed within the outer edge of the assigned area. The turbine itself will then be located less than 1 km from the outer edge of the area and the total distance between turbines in the various areas will be closer to 5 km.

Based on this, we will propose the following alternative divisions of Utsira Nord. In both proposals, we have assumed that development is currently limited to a total installed output of 1,500 MW.

Alternative 1: Recommended proposal for area division - without a military training field

In this alternative, Utsira Nord is primarily divided into three areas, two areas north of the pipeline and one area south of the pipeline, see appendix 1. This is our preferred alternative.

The advantages of this division are:

• Subdivision with large areas promotes industrial development and facilitates cost reduction
• The division will ensure a high capacity factor
• There is sufficient distance to the Johan Sverdrup pipeline
• Provides great flexibility for optimizing the individual fields within the indicated limits
• Installed power in the three areas can be distributed equally with up to 500MW in each area or adjusted individually within the limit of 1500 MW with two larger areas north of the gas pipeline field and one somewhat smaller area south of the pipeline.

Alternative 1 provides a division with an equal capacity limit and thus approximately equal production for the three areas. Each of the areas is given a limit of 500 MW and the area is calculated to provide an approximately equal capacity factor.

As previously described, scale and volume are a decisive factor for industrialization and cost reduction. The potential for efficiency, industrialization and cost reductions increases with the size of the wind farm. An alternative solution would be to adjust the areas within the limit of 15OO MW and establish two larger areas, one large area in the north and one in the south. The area in the south can consist of areas partly south and partly north of the pipeline, and the design of the area must also in this case take account of the gas pipe.

Alternative 2: Recommended proposal for area division - with a military training field

With a military training field, it is still possible to establish solutions for 1500 MW, but as a result of increased density of turbines, the capacity, and thus the economy of the projects, will be reduced. Floating offshore wind projects are still dependent on financial support to be realized and reduced economy in the projects will increase the need for support.

With limited area available as a result of the military shooting and training range, we do not see it as appropriate to divide Utsira Nord into more than two areas. This is to reduce the area occupied by buffer zones and improve capacity. In this case, we also propose to use the gas pipeline as a starting point and use this area as a buffer zone, and establish two large areas on opposite sides of the pipeline for the best possible utilization of the available area. Capacity for the two areas can then be set according to the area allocated.

Read the response to the consultation on OED's website here.

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