Notice on the initiation of the procedure for amending and updating the Site Development Plan (FEP) pursuant to Section 8 of the Offshore Wind Energy Act (WindSeeG)
Statement — Summary:
– AquaVentus welcomes the fact that sufficient sites remain available in Zones 4 and 5 to make the prospect of up to 10 GW of electrolysis capacity at sea appear feasible. The long planning horizons call for flexibility in sectoral planning here — determinations that are not strictly necessary should therefore be avoided.
– We also welcome the fact that the concept for a national and European collector pipeline, integrating hydrogen potential from both SEN areas and North Sea riparian states, has been further specified and that routing through the border corridors has been made more flexible.
– Site development planning should ensure that the connection of the already designated SEN-1 area, as well as of further possible SEN areas, to the hydrogen collector pipeline can be planned as efficiently and as promptly as possible.
1. Long planning horizons call for flexibility in sectoral planning in order to achieve capacity expansion and climate protection targets as effectively as possible
The AquaVentus Förderverein emphasises that, in order to achieve the climate protection targets and in the interests of energy security, the limited site potential of the German EEZ in the North and Baltic Seas must be used as efficiently as possible. In this respect it is right that the Site Development Plan makes consistent use of the sea area available for offshore wind expansion. At the same time, however, the FEP's intended planning horizon extending to at least 2037 is exceptionally long and is accordingly subject to considerable technological, economic and regulatory uncertainty. Future developments cannot be reliably accounted for and anticipated today. For this reason, comparable planning documents — such as the Network Development Plan — set out scenarios for how the underlying assumptions may evolve, in order to allow the greatest possible flexibility of response over time.
Various studies, such as those by AFRY or DNV, underline the considerable advantages of the concept pursued by AquaVentus of up to 10 GW of electrolysis capacity in the areas of the German EEZ far from the mainland. The speed of expansion is increased significantly, investment costs fall and critical environmental impact is reduced to a minimum. In addition, the Fraunhofer IWES study on offshore site potential underlines how, in the interests of climate protection, greater overall capacity and higher site efficiency can be achieved through repowering or co-use. Harnessing these advantages represents a technical, ecological and economic opportunity to make urgently needed green hydrogen available offshore in large quantities and with security of supply, but it depends on the regulatory framework being created for it. The latitude available under the WindSeeG should therefore be used, and further sites should not be conclusively determined prematurely.
When determining the further sites west of SN 10, the potential of offshore hydrogen and of potential additional sites should therefore be given adequate consideration. This, however, presupposes a longer and open-ended stakeholder dialogue as well as political steering. From the perspective of AquaVentus it is therefore decisive that the outcome of such a dialogue can feed into the further sectoral planning, so that the necessary determinations can be developed from it.
2. Collector pipeline. AquaVentus welcomes the fact that the revision of the FEP enables the generation of hydrogen offshore with subsequent transport via an adequately dimensioned hydrogen collector pipeline. This opens up the necessary perspective for implementing the AquaVentus concept of 10 GW of hydrogen offshore and represents an important regulatory milestone for the initiative. The clarifications in Chapter 8 are helpful in this regard, but not yet sufficient. Very welcome, however, is the greater flexibility regarding the use of the border corridors, which facilitates routing. It is entirely comprehensible to us that further coordination with the neighbouring states adjoining the German EEZ is required in order to realise the highly expedient prospect of using the hydrogen collector pipeline for European interconnection.
3. Connection of the SEN sites. In line with the considerations on the laying of power lines, comparable thought should be given to connecting the SEN sites via a hydrogen collector pipeline. It is of outstanding economic and ecological importance that a spatially efficient connection be achieved here, placing as little burden as possible on the SEN projects and the marine environment. Protecting the marine environment is not only a central objective for AquaVentus in its own right, but at the same time an essential building block for public acceptance.