The Green Warriors of Norway's consultation response offshore wind Southern North Sea II and Utsira Nord

The government has advanced and disregarded all input and consequences in the process to develop offshore wind at Utsira Nord and Sørlige Nordsjø II. Namely, they must hand out licenses and subsidies before the areas are to be examined for licenses at all. This is definitely not an acceptable procedure in a democratic society. There are such large negative social and environmental consequences associated with this that the processes should have been stopped or paused. The precautionary principle must lie at the bottom of all major decisions.

The Green Warriors of Norway (NMF) finds the government's approach completely unacceptable and has designed the consultation responses accordingly. In the consultation responses on Sørlige Nordsjø II and Utsira Nord, NMF demands that the further licensing processes be stopped.

The premise for the processes as laid out by the government follows the "table catches" model, where one has already decided on development, and where all impact assessments are only pro-forma without any significance for the further processes. Where "adjustments" are made, these will only be superficial and almost without any value, given the content of the consultation letters and the government's statements in the media. You have decided on the development before you have collected data. Commitments are given and agreements are made in advance, which will put the licensing authority in a position where it must be able to anticipate that there will be liability for damages if impact assessments can place restrictions on the developer/concession holder. There are such great environmental consequences, and social consequences, including consequences for the already strained supply situation, that it would be downright unjustifiable to proceed with these processes at this time. Better to put these processes on hold now than to put yourself in a situation where you are forced to continue despite unsustainable consequences for the environment, society and security of supply.

Contrary to the Aarhus Convention

The government overrides its own energy commission. The Energy Commission conducted a digital input round on 10 May, and the deadline for written input is set for 25 May. Nevertheless, the Government chooses to bypass its own Energy Commission by present the offshore wind investment of the times the day after the digital input meeting, on 11 May. The government thereby deprives the Norwegian population, organization Norway and other affected and interested parties of participation in the decision-making processes that have the greatest significance for Norwegian energy and environmental policy. This is not only an overrunning and bypassing of all democratic principles, but is directly contrary to of the Aarhus Convention objectives, and especially i Article 1 (Target setting), and 7. (Public participation in connection with plans, programs and strategies regarding the environment). The whole process, including this hearing, is undemocratic and only pro-forma to give the impression of democracy, while it all seems predetermined. Why should the Norwegian people and organizations be invited for input and information on Norwegian energy policy, when the major decisions are made outside anyway? The input that has been prepared and submitted to the energy commission to survey the current situation and with proposed solutions is thus rendered worthless by the current government. Is democracy too troublesome for the Government?

Threatens food safety

The offshore wind developments on Sørlige Nordsjø II, as well as on Utsira Nord, are in breach of the obligations to The UN's Sustainable Development Goals, and in particular sub-goal 14 Life in the ocean. In a time of great uncertainty around food production, the global food and supply crisis, etc., one does not bet on things that threaten the very carrying capacity of our vulnerable marine ecosystems. Offshore wind occupies an enormous area, pollutes the marine environment with noise, and electromagnetic fields from large networks with submarine cables, pollutes with microplastics which can also contain large amounts of the dangerous the hormone disruptor Bisphenol-A, the eternal poison PFAS and other toxins. This recently launched offshore wind venture comes at the expense of and is a direct threat to The UN's Sustainable Development Goals, sub-goal 14 Life in the sea. As a nation, Norway has an international responsibility for and manages one of the world's largest and most productive sea areas, which must be able to feed an ever-growing population.

Additional wind power in the region (NO2) which has the greatest exchange with Northern Europe is redundant

Wind power, which is both an unstable and unpredictable source of energy, is not suitable for Norwegian power supply. What has already been built and put into operation is already putting maximum pressure on the stability of energy supplies. There is no room for more wind power, whether it comes on land or at sea. Especially not as Norway is already connected with a significant capacity for power transmission via the foreign cables which have now opened up the southern power regions directly to the markets in England and on the continent. The power that is intended to be produced at Sørlige Nordsjø II and at Utsira Nord enters the same region (NO2) that has the largest power exchange. At the same time that these two fields are also located within more or less the same geographical weather area, the fluctuations in electricity production will also largely coincide with wind power production in, for example, Denmark, northern Germany and the Netherlands. If there is a lot of wind in these countries, it tends to blow a similar amount at both Sørlige Nordsjø II and at Utsira Nord, and correspondingly when there is little wind. This means that the excess capacity that already exists in the area of Denmark/Northern Germany will at the same time also provide excess capacity in the entire NO2 region, including the announced offshore wind farms Sørlige Nordsjø II and Utsira Nord. We have near-free power exchange and with further development of wind power in the same weather and exchange area will thus become completely redundant.

What is called "dunkelflaute" in German is when there is no wind and it is both dark and cold at the same time. Conversely, in periods of high wind, too much wind power is actually produced in Northern Europe. It therefore makes little sense for Norway to build out even more of the same that does not work further south and within the same power exchange and weather zone that already has excess capacity at the same times as there is also excess capacity in NO2. This the article by Bernt Pedersen in DN 09.12.2022 explains this in more detail. Also within the same energy range German authorities pay 807 million euros annually to German wind power plants so that they will stand still and not produce when it is windy, mainly for wind power plants in Lower Saxony and in Schleswig-Holstein. And as if this is not enough, so German authorities also pay Danish wind power plants to stand still and not produce when it is windy.

Utsira Nord and Sørlige Nordsjø II are located in the exact weather and power exchange area for which the German authorities pay several hundred million Euros annually for wind turbines to stand still and not produce when it is windy...

The climate benefits that blew away

It makes absolutely no sense to develop more wind power within the same exchange area (Nord Pool) which already has a significant excess capacity. This means that all the climate costs of mining, production, assembly, operation, maintenance etc. for wind power plants associated with region NO2 and Denmark/Germany/Netherlands will be completely redundant and at the same time also a gigantic climate burden that we in an enlightened society in 2023 should save ourselves from. This will therefore be a purely negative climate measure that will constitute a large negative item in our national climate accounts. You cannot calculate climate benefits for something that costs large amounts of CO2 to produce, and which is also completely redundant and wasted. These developments on Sørlige Nordsjø II and on Utsira Nord thus appear to be completely pointless and unnecessary. Not only do they constitute a completely unnecessary climate burden, but also as a probable environmental disaster of large dimensions, and as a gigantic cost sink that must be covered by Norwegian electricity customers and taxpayers through perpetually high electricity prices, unstable energy supply and potentially large public subsidies straight from the common coffers.

No room for more unstable energy in the grid

NVE also warns in its report; Norwegian and Nordic impact balance until 2030 (NVE report 20/2022, chapter 3.3) against the fact that major imbalances in the power supply today can worsen with increased wind power production.

"Very large imbalances occur from time to time in Norway and/or the Nordic region. Sometimes the imbalances are over 3,000 MW, see Figure 19. This is very much compared to Norwegian regulating power reserves of around 1,800 MW (in addition to the reserves in the other Nordic countries). Typical reasons for such deviations can be major errors in the forecasts for wind power and consumption, or the failure of a major power plant that lasts a long time. Another reason is skewed flow, which means that the real flow deviates from the flow calculated in the market clearing. This is because the model with bidding areas is not always good enough to represent the physical conditions in the network correctly. The increase in wind power production in both the Nordics and Northern Europe is expected to lead to further increases in the imbalances in Norway and the Nordics. Large imbalances are problematic because in such a situation the TSOs use up the regulating power bids for balancing. There will then be few reserves left to handle a larger outcome. This is exacerbated by the fact that the imbalances tend to occur in areas other than the reserves, which can lead to deficits in individual areas, typically NO1. Here there is high demand and little production and thus little reserves. This makes NO1 dependent on imports from other areas."

At the same time, it is also in the same weather and exchange area that there is already excess capacity of unstable wind power in Denmark/Germany/Netherlands, within which both these developments on Sørlige Nordsjø II and Utsira Nord fall. When the imbalances in the Nordic region are already over 3,000 MW, and the developments on Utsira Nord and Sørlige North Sea II are stipulated at 1,500 MW and 3,000 MW respectively at maximum development, it is easy to imagine that this will lead to several catastrophic situations with significant imbalances when the Norwegian regulating power reserves are only 1,800 MW. If you add up the 3,000 MW you already have in imbalances with new unstable wind power/offshore wind, this is quite a significant figure in overall imbalances.

"If the production is less than the load, the frequency drops. Reserves for up-regulation are used to increase production or reduce load when the frequency drops. Especially in the case of large imbalances, it happens that the supply of reserves is less than the minimum requirement to cover dimensioning errors, or that available reserves are trapped behind bottlenecks, often in NO2 and NO5.".

At the same time, NO2 is the same energy region that will receive power from the two fields, while it is also NO2 that has the greatest export exposure to the same countries that already have excess capacity within the same weather area. Regular blackouts and extreme price fluctuations can therefore be expected to become normal everyday life for Norwegian companies and electricity customers in the years to come if this process of offshore wind on the Southern North Sea II and on Utsira Nord is not managed to be stopped, in addition to all the other wind power issues that lie and wakes in the water crust in several of the Norwegian municipalities. If the goal was to destroy the power supply in Norway and weaken Norwegian competitiveness and social structure in favor of foreign state power, then this is certainly the way to go. For anyone who sees how wrong this is going, these processes must be stopped immediately.

Price shock and weakened competitiveness

In autumn 2022, Norwegian electricity customers received a price shock for energy the likes of which we have never seen. Not only does this weaken the purchasing power of ordinary citizens, but to a very large extent also Norwegian workplaces that previously had a competitive advantage over the markets in which we compete with reasonable strength, saw this competitive power disappear and also periodically experience significantly higher electricity prices in Norway than in Europe. It was precisely this for which we have already sacrificed all the highest and most majestic waterfalls and waterways. It was this that secured us both prosperity, industrial development and competitiveness. Now all this has been blown away with the wind, literally. Not only have we now connected our country to the European electricity market at almost full capacity, but we have also introduced a significant amount of instability into our own energy supply through the large-scale development of unstable and unpredictable wind power. When everything indicates that we are about to pass the point where we can no longer control further instability, we should immediately pull the emergency brake and take stock. But this is not what the government is now doing with a gigantic investment in unstable offshore wind in the same weather area where there is already considerable excess capacity. We thus end up with a very expensive development that destroys absolutely all stability in the power supply and with a very negative environmental consequence with something that is completely unnecessary and that becomes a purely negative climate burden. And as if all this is not enough, one has already decided in advance and before one's own energy commission can analyze the current situation and make recommendations for future measures and solutions. Here, both the UN's sustainability goals, the stability of Norwegian energy supply, democracy and everything else are thrown directly into the sea. And the climate targets are set back thoroughly as a result of the fact that all this offshore wind investment comes on top of a significant excess capacity within the same periods that the German authorities are already paying hundreds of millions of Euros annually for already developed wind power plants to stand still and not produce when it is windy. Absolutely incredible.

Excessive development with major consequences

And when the entire development becomes redundant and unnecessary, all the consequences become completely unnecessary at the same time. You burden the climate completely unnecessarily. The marine ecosystems, including adjacent or overlapping spawning areas for kingfish or other species, are threatened by noise, pollution (microplastics/PFAS/Bisphenol-A etc.), electromagnetic noise from a whole network of electrical cables on the seabed. The entire energy supply is threatened with critical instability. Electricity prices will be constantly high. The government will provide large subsidies for investment and/or guarantee high electricity prices and possibly cover the difference from the joint fund if electricity prices should be lower.

Springboard for the establishment of new species - a threat to existing spawning areas for sandpipers etc

It is argued in several places that offshore wind is good for fish because the developed areas are spared from trawling and fishing. In addition, an offshore wind farm will also be able to function as an artificial fishing reef. Both of these are completely and utterly wrong arguments. Firstly, fishing is already regulated for geographical areas, where there is full opportunity to place further restrictions either through protection or through the allocation or reduction of quotas or species within the geographical areas where there should be a need for this. One certainly does not need the development of environmentally harmful offshore wind to achieve this. We already have the mechanisms you need through legislation and regulations. When it comes to artificial fishing reefs, there may well be a higher concentration of certain fish species within an offshore wind farm, but these are often predators on the hunt. Noise and electromagnetic fields etc could constitute a significant area of conflict vs spawning. This warns, among other things, The Institute of Marine Research against.

"On the other hand, such reefs can also act as a springboard for alien species, so that they can spread to new areas where they do not naturally belong.".

We are now in a situation where higher sea temperatures can lead to new species, which do not naturally belong here, being introduced and gaining a foothold in Norwegian waters. In recent years, we have seen exactly this, where several more tropical species have been caught in our waters and in greater frequency and quantities than ever before. Sørlige North Sea II are adjacent and partly overlapping spawning areas for the key species sandpipers. Here, they will be threatened both directly by noise and electromagnetic fields over large parts of the seabed, but also by the fact that larger numbers of predators can be established that can conceivably make inroads into the stocks before they can spawn. This could have unforeseen consequences as fish species such as sole are also the very basis for other species such as pollock and various other species of codfish. If the food for the cod is threatened, the carrying capacity of our important sea areas is also threatened. In a situation where war and the availability of fertiliser, etc. threaten the world's food production, it would be completely reprehensible to bet on something that could threaten our own food production. Also remember that Norway depends on importing between 60-70% of all the food we eat. We certainly cannot afford to risk this for short-sighted symbolic measures with disastrous consequences.

A significant source of pollution for microplastics, PFAS and Bisphenol-A

At the same time, wind power is also a significant source of microplastic pollution, via erosion from turbine blades and paint etc. When we have to reduce all existing sources, it makes absolutely no sense to introduce several completely new sources that will contribute to even more pollution. The problems with erosion are significantly greater than what the industry itself states, and which the authorities also take for good fish. NMF has documented that this problem is significant, and also that it is also further intensified in our demanding climatic areas. Furthermore, we document in our consultation responses to ECHA and the Norwegian Environment Agency that the industry also controls most of the existing knowledge base, as shown in two reports, from Korea and from Sweden. Not only is the turbine blades' epoxy composite a significant source of emissions of the dangerous endocrine-disrupting environmental toxin Bisphenol-A, but also the outer coating also contains quantities of the non-degradable environmental toxins PFAS. All these substances are on the EU's list of substances of great concern and which face strong restrictions. All the deployment of new wind power thus become potential new sources for emissions of these worrying substances. Microplastics in themselves are also a significant problem as they find their way into all parts of the environment and into food chains. As the emissions of microplastics do not break down in nature, they pile up and accumulate, emission after emission and year after year. Our most important task now is to reduce existing emissions and prevent the creation of new ones.

Norwegian energy policy…


When the iceberg appears on the radar in front of the Titanic, the best solution would be to slow down and change course. This government instead aims directly at the iceberg and gives maximum throttle on all engines. Norwegian competitiveness and the stability of the energy supply are being destroyed. The same happens with nature and the carrying capacity of the vulnerable marine sea areas that Norway has an international responsibility to take care of. All this with a very expensive measure that burdens the climate unnecessarily and will remain a gigantic climate burden for the foreseeable future. All further processes with Sørlige Nordsjø II and Utsira Nord must therefore be stopped.

The establishment of an energy commission is a complete waste when at the same time you rush all this work by making all the big decisions before you have taken the time to listen to input or to survey the situation and possibilities. Such an undemocratic process is also directly contrary to the Aarhus Convention's obligations regarding participation in environmental matters.

The Green Warriors of Norway demands a complete shutdown

The Green Warriors of Norway demands a complete halt to all processing and further processes at these developments. Instead, the Government must focus on sensible energy measures, and in particular on the utilization of stable heat energy from the earth, both for direct heating, and for geothermal electricity production. As the nation that has the leading technology and expertise in deep drilling from the North Sea, Norway is also the most natural country to invest in the utilization of geothermal energy. This is what will be a real transformation of the accumulated expertise and technology from the North Sea into a stable renewable energy source that can become absolutely central when the energy systems of the future are to be built here in Norway, and could also be exported and built abroad in other parts of the world.

While the development of geothermal systems is progressing at express speed elsewhere in the world, the Norwegian expertise community is left on the platform waiting for a rain of free subsidy money to rain down on an offshore wind venture that is not only completely redundant, but is also a gigantic dead end in relation to to the development of future energy systems. The unstable wind power becomes like the dying dinosaurs that disappear from the tree trunk of evolution, while utilization of the heat resources that are available underground becomes the solution to the energy challenges of the future. We have the best expertise and the best technology environments. Let's not waste them on subsidies or on climate and environmentally damaging solutions. We are completely against subsidizing climate-damaging environmental destruction.

NMF demands a complete halt in the processes of offshore wind/wind power on Sørlige Nordsjø II and on Utsira Nord, and instead wants full investment in exploitation and development of geothermal energy as the stable and environmentally friendly energy supply of the future.


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