Αρχική Διατάξεις για την απλοποίηση της περιβαλλοντικής αδειοδότησης, των περιβαλλοντικών επιθεωρήσεων και την προστασία του περιβάλλοντοςΚΕΦΑΛΑΙΟ Η’ ΠΛΑΙΣΙΟ ΑΝΑΠΤΥΞΗΣ ΥΠΕΡΑΚΤΙΩΝ ΑΙΟΛΙΚΩΝ ΠΑΡΚΩΝ (άρθρα 59-75)Σχόλιο του χρήστη Seawind Ocean Technology | 14 Ιουλίου 2022, 12:34
  • Σχόλιο του χρήστη 'Seawind Ocean Technology' | 14 Ιουλίου 2022, 12:34

    Seawind Ocean Technology comments to the public consultation Introduction - Seawind company profile and description of our proposed project for Greece: Seawind Ocean Technology is a technology development company and Original Equipment Manufacturer (OEM) founded in 2014, producing the new generation of floating fully-integrated wind turbines. The company is legally registered in the Netherlands. In essence, we are a truly European company with more than 11 nationalities in a team of 50 employees. For more information, please visit our web www.seawindtechnology.com In Europe, we are active in France, Italy, Greece, Portugal and the UK. In the rest of the world, we are present in the USA, Japan, Malaysia and the Philippines. In the said countries we are currently marketing our two floating wind turbine units, Seawind 6 (6,2 MW) and Seawind 12 (12,2 MW). Both are two-bladed wind turbines with a teetering hinge on a semi-submersible concrete floating foundation. We provide the full integrated floating wind turbine system installed at sea which can be deployed in deep and ultra-deep waters (from 60+ meters up to 3,000 meters) accessing abundant, high-speed, low intermittent wind resources. We own our IP, have 28 patents and 12 are pending. The leading certification society Den Norske Veritas (DNV) has qualified our technology for the certification process in 2019. Seawind’s vision can be summarised in these words: we are dedicated to deep decarbonisation by redefining the global offshore wind energy industry and to generate clean, affordable and reliable energy at large scale. We also believe that local communities and economies must directly benefit from locally-based projects so in our business plan we prioritise local content favouring a local construction and assembly approach. We are convinced that while electrification is a one-way street for cleaner energy and eventually net zero emissions, at the same time there are important activities (e.g. maritime and airborne transportation, heat for thermal industrial and services purposes etc.) where electric power cannot replace fossil fuels. A different type of energy will be needed there. In this context, while Seawind is gearing up for the large-scale demonstration of our floating wind turbine technology for power generation in the beginning of 2024, we are also working for the development of our larger floating wind turbine Seawind 16 (16 MW) in parallel with the offshore production of green hydrogen using wind power generated by the said model as feedstock for electrolysis of purified sea water. This is what we want to do in Greece, specifically in the island of Crete. For the island of Crete Seawind is putting forward a proposal for a 300 MW floating offshore wind park that will produce electricity to be utilised solely for the production of green hydrogen (project ICARUS). We foresee delivery of this project by the end of the present decade. We have consulted with relevant stakeholders in the island and believe that the island’s energy needs will be better served by green hydrogen rather than by continuing the use of diesel and LPG. We also monitor ongoing developments internationally whereupon the green electrification of oil and gas assets used for offshore exploration is becoming a reality (e.g. the United Kingdom and Norway). Given the expected major exploration activity in the western part of Crete, Seawind’s proposed business plan will also deliver lower emissions related to offshore oil and gas exploration, thereby increasing the longevity of the said assets and accordingly prolonging further into time the economic benefits associated with their exploration for Greece’s economy. As a company we have both very strong environmental instincts and we wish to have no negative impacts on local economies and societies. Therefore, ICARUS will be located beyond a 30 km radius from the nearest shore in the island, to avoid any impact on tourism and small-scale fishing. Because our produced electricity will be completely utilised for green hydrogen production, we do not intend to be interconnected to the power transmission network. Rather we will connect our wind park with a dedicated private HV cable to the hydrogen production unit. General comments about the Framework for Offshore Wind in Greece: We welcome the proposed Framework. We support its objectives and the overall design of the process leading to licensing while at the same time paying appropriate attention to environmental issues. We consider the role of the HHRM as key to this effort; they are experts in this area and have the right people to ensure delivery and business-like conduct. We also fully support the role of the RAE in this Framework, also due to the high-quality personnel, but it should be also pointed out that RAE needs further staffing support. Our comments seek to build onto to the proposed Framework. We do not seek to change it, but rather complement it. We believe that the present proposed Framework for Offshore Wind can be further improved by including our option: using electricity from offshore wind parks for hydrogen generation and not connecting the power generated to the national electricity network. In fact, green hydrogen production is expected to be a key storage option for floating wind. In this sense, what we are proposing will render the proposed Framework more innovative and forward-looking. See detailed comments below. We would also underline the fact that the offshore wind market is dynamic where the floating wind segment in particular is very promising, but very young too. This position paper from the European Wind Power Association, WindEurope, on floating offshore wind provides detailed information about the leading role of Europe in this area, but also the fact that it is only since 2017 that floating wind operations have started and that we are still at a relatively early stage: 'Floating Offshore Wind Energy A Policy Blueprint For Europe' (windeurope.org) https://windeurope.org/wp-content/uploads/files/policy/position-papers/Floating-offshore-wind-energy-a-policy-blueprint-for-Europe.pdf#:~:text=Floating%20offshore%20wind%20%28FOW%29%20is%20a%20fast-maturing%20technology,needed%20to%20make%20it%20a%20European%20success%20story In this sense, we see the proposed prerequisite of 10 years’ operation of a floating wind technology for the acquisition of a license as unrealistic and wrong. We would rather propose that for floating wind specific operations this criterion is replaced by technology certification by a world-recognised certification society to demonstrate that the said floating wind technology is reliable (by given proof of concept and the corresponding Technology Readiness Level). This argument also stands for the requirement-prerequisite of operation of at least 100 MWs and the associated business turnover. For floating wind, globally there are less than 100 MWs of capacity at present, hence this value too is not correct. Conversely, the situation is different for fixed-base offshore wind turbines where there is a longer history of development and the corresponding market size. The above preconditions make sense for the fixed-base market applicants. Fixed-base offshore turbines will represent, nevertheless, a much smaller share in the Greek offshore wind market. In this sense, both the 10-year, the 100 MW and the turnover provisions are discriminatory and prohibiting younger, innovative and potentially more competitive parties from entering the developing floating offshore wind market in Greece. This is not levelling the playing field and we strongly insist that the three provisions will be removed for the floating offshore wind market segment that corresponds to the Framework. In sum, different criteria will need to apply for fixed-base and for floating wind, reflecting the status of development of each technology and market, which are globally recognized as quite different in terms of technology and the associated business models. In conclusion to our introductory comments, Seawind welcomes the opportunity to further explain our points to the Greek authorities. We are convinced that the Greek offshore wind market can deliver affordable, abundant and sustainable energy for Greece and for the SE Med region as a whole. We believe that our proposed project ICARUS can elevate the potential benefits associated with offshore wind generation by bringing green hydrogen into this equation. In this context, we strongly support that the proposed Framework is appropriately forward-looking and supportive of innovation by levelling the playing field among fixed-base wind turbine and floating wind operators and allowing sufficient space for those projects that will not have electricity as the final product. Please find our specific comments as per article below: Article 59: Definitions Para 3. Associated activities to an offshore wind park: As presented in the previous section we do not see the need to define an offshore wind farm as necessarily connected to the electricity network. In this sense, and in Seawind’s case specifically, any costs associated with the transmission of the power generated will be covered by our company and will concern transporting the generated electricity from point A (wind farm) to point B (hydrogen production unit). The Framework should also consider this arrangement and accordingly remove associated licensing and planning studies and fees related to interconnection with the Greek power transmission network. The above points also apply with reference to the provisions of Art. 68 ‘System interconnection’. **** Article 61: Planning of Offshore Wind Parks Para 4. Environmental Impact Assessment: We fully support the prioritisation of low environmental impact associated with the installation and operation of wind turbines at sea. Seawind’s floating wind turbines have been designed with this in mind; we have selected materials that positively interact with marine ecosystems, namely concrete, instead of steel for our floating foundation (our turbine’s platform) and we choose to go to the deeper seas to avoid any impacts on migratory birds. **** Article 63: Arrangements for acquisition of a ‘survey license’ Para 5. Applications and criteria for eligibility: professional and technical capabilities Seawind disagrees with the establishment of the same criterion for two different in terms of maturity and size technologies, namely fixed-base and floating offshore wind. The 10-year operation experience criterion is completely impossible for any floating wind operator and so is the 100 MW operation criterion as well. The above point also applies to what concerns the revenues criterion. For companies, such as Seawind, dedicated to floating wind turbines only, the turnover value in the draft Framework is prohibitive and discriminatory. It favours fixed-base offshore wind turbine companies that will nevertheless be called to develop primarily floating wind farms in Greece. This needs to be corrected in the proposed Framework to ensure that those that possess the right technology for the Greek offshore wind market (almost totally to be floating) can enter the market and deliver cost-efficiently, technically correctly and with innovation in mind. **** Art. 66. Competitive process for the selection of an Offshore Wind Park Investor Seawind is of the opinion that the Framework should include the option that in certain offshore locations already reserved for other economic activities private agreements can be concluded outside the defined competitive procedure, since the rights to these locations are with private parties. In this context, the exploitation of these locations should not be subject to the RAE competitive bidding process. In this logic, projects located in these areas will neither seek connection to the national transmission network and nor seek to benefit from the guaranteed price for the produced electricity. As is already the case for use of sea area in Italy and in Portugal, a fee to the Greek State of reasonable cost can be applied for the duration of the specific project. -