Due to the changing security situation in the world, Defense is focusing more on defending our territory and that of our NATO allies. This requires a larger, better equipped and well-trained armed force and more space, physically and indirectly (for example for noise and nitrogen). To this end, Defense maps out, via the national policy vision, what space the armed forces need and expect to need in the future within the broader framework of the National Space Program for Defense (NPRD) . The NWEA (now NedZero) has submitted the following opinion in order to pay extra attention to the energy transition.
Utrecht, February 12, 2024. The Dutch Wind Energy Association (NWEA) (now NedZero) would like to take advantage of the opportunity to submit a view on the Memorandum on the Scope and Level of Detail of the National Space Program for Defense. The NRD provides a good overview of the changing needs of Defense and is sensitive to the fact that the Netherlands is faced with several urgent spatial issues that often (physically) get in the way of each other. Linking opportunities, combination use and accommodation are therefore the motto!
Several members of NedZero submitted their views on their own initiative. NedZero endorses these views and refers to them for specific projects and insights. This view is intended as a supplement to this and as an encouragement to convert the importance that Defense attaches to the NRD into concrete efforts to deal smartly, flexibly and pragmatically with the various spatial tasks in the Netherlands.
From our supporters, the wind energy sector, we would like to draw additional attention to the fact that the Energy Transition plays a crucial role in securing a sustainable future for our society. Without a widely available, robust, clean energy supply, the high-tech society as we know it comes to a standstill. Our final energy consumption must be 100% low-CO2 (we are now at 17%).
Creative planning is necessary for efficient use of space
Offshore and onshore wind energy will supply the bulk of this clean energy, supplemented with solar energy, nuclear energy, geothermal energy, green gas, hydrogen and other forms of energy generation and storage. This requires space and this space requirement is partly incompatible with that of Defense. Low flying areas, training areas and helicopter landing sites in particular are not, at first glance, a good match with wind turbines in the immediate vicinity. Defense radars are also difficult to combine with wind farms.
At the same time, creative planning also creates linking opportunities that can simultaneously support the activities of Defense and the Energy Transition. In our opinion, the balance of interests between Energy Transition and Defense's space needs can be optimally achieved by taking into account two categories of linking opportunities and two organizing principles:
- Link opportunity 1: Defense 'locates' with existing energy infrastructure
- Linking opportunity 2: Defense helps design new energy infrastructure when taking up new space
- Organizing principle 1: Coordination with other ministries and their spatial plans
- Organizing principle 2: Defense makes an ultimate effort to spare as many search areas as possible for energy generation, and explicitly takes the generation potential of a specific search area into account when weighing up interests
Link opportunity 1: Defense 'locates' with existing energy infrastructure
A number of activities for which Defense is looking for space place few demands on the quality of the environment. It is worth considering for these needs the proximity of, for example, existing wind farms. These are often located in rural areas with an open character, with relatively few local residents, and already include a safety and noise contour around them. Any Defense need that can be met in or directly adjacent to these wind farms makes useful use of space that cannot in any case be made suitable for habitation or rugged nature, for example (attracts bird victims and tall trees hinder the yield of turbines).
Points of attention here are:
- Local support;
- the safety contour PR 10-5 or 10-6 around wind farms, with any domino effects that are introduced with the arrival of Defense activities.
- accessibility for regular maintenance and in the long term: demolition or repowering of the wind farm;
- the noise production and cast shadows that can occur at wind farms. It is difficult for NedZero to estimate to what extent these aspects influence the activities that Defense wants to accommodate.
For Defense's maritime activities, we would like to point out that the further expansion of the offshore wind energy area places new requirements on ports and the (international) supply chain. Perhaps expanding and deepening existing ports will also offer new planning opportunities for Defense, where the need for space and site security can be shared. NedZero has good experiences with Defense with regard to search area 4, where Defense wants to guarantee the preservation of training area EHD42 and sustainability by jointly examining what agreements are needed to create a wind farm in this area while maintaining the training area.
Matching opportunity 2: Defense helps design energy infrastructure when taking up new space
Defense will also electrify to a significant extent, and that will require new (heavy)
electricity connections at Defense locations. Given the current problem of grid congestion, delays in this area are to be expected. It would therefore be good if Defense worked on generating energy on its own premises. With wind turbines where possible, with solar panels on roofs and facades and with space for pipes and transformer stations that may serve more than just the defense location itself. The point of attention here is that energy infrastructure must be able to be maintained and repaired. In this way, Defense can at least partly compensate for the loss of generation potential associated with establishing new low-flying areas and other activities, insofar as these prevent the development of new sustainable energy projects.
The advice is therefore: in the further elaboration of the NRD, consider what a greening of the armed forces, especially in the form of renewable energy, could mean. Both to reduce the footprint of the armed forces and to provide the opportunity to operate more independently in crisis situations.
Organizing principle 1: Coordination with other ministries and their spatial plans
National planning and organizational processes are underway in several policy areas. The National Regional Energy Strategy Program (NPRES), the National Energy System Program (NPE) and the Main Energy Infrastructure Program (PEH) are important specifically for the Energy Transition. National plans have also been published or are in the making for other domains such as housing, mobility, space for water and nature. We are confident that there will be sufficient coordination at ministerial level.
We do ask for extra attention to be paid to provincial and municipal spatial policy, specifically where search areas for wind energy are concerned. These search areas are sometimes created under great pressure and polarization, and if they are thwarted by Defense plans, the damage to that process is incalculable. That would be completely unpleasant if Defense ultimately chooses a different option. Caution and diplomacy are therefore required!
Organizing principle 2: Defense makes an ultimate effort to spare as many search areas as possible for energy generation, and explicitly takes the generation potential of a specific search area into account when weighing up interests
If it is unavoidable that a search area for sustainable energy comes into the picture for Defense activities and linking opportunities are not possible, then we urge you to take this into account in the decision:
- How much potentially generated energy will this cost?
- How advanced is the energy generation planning?
- How extensive are the options for the relevant RES region/province to compensate for the loss of a specific location with another location?
- What is the impact of Defense plans on the strategy of the regional grid operator and Tennet for this region?
In cases where several Defense search areas overlap with wind search areas, NedZero asks to choose the areas that can most easily be compensated regionally.
Additional suggestions and questions
- Consider the presence of sustainable energy infrastructure as a fact of life and explicitly include its presence in training regimes. After all, wind turbines are also being installed in other countries and it is highly conceivable that the tactical deployment of men and equipment will have to take place in their immediate vicinity. A concrete example: Even in real crisis situations, pilots must take into account high objects and, for example, helicopters from countries near or between wind turbines. Wind turbines are also ideally suited to familiarize pilots with night vision goggles . Further elaboration should therefore focus on solutions that do not impose (future) restrictions on the energy transition.
- Placing wind turbines very close to a built-up area seems impracticable from a planning and legal perspective. While such a placement can provide interesting information about (mitigation of) noise levels indoors. Perhaps Defense sees opportunities for installing wind turbines at a training village, where scientists can further investigate the influence of wind energy on the built environment?
- Chapter 11 describes the need for low-flying areas for helicopters. Two options are being further investigated: a stricter legal-planning regime in existing areas and/or the designation of new areas. The accompanying text describes that variety in areas and within areas is of great importance in the context of training. Why a stricter legal-planning framework would be necessary in existing areas and what that would look like is not explained. This should still be clarified.
- With regard to new low-flying areas for helicopters, it is not stated whether and, if so, to what restrictions this could lead to the areas. Since a strict legal planning regime is envisaged for existing areas, it can be assumed that there will be forms of restrictions, although it is described as a 'light regime'. What this means should be clarified.
- The new low-flying area in the southwest of the Netherlands is an area where many wind turbines (often in clusters) are already located or planned. Designating a low-flying area should not lead to restrictions on development for the energy transition. Clarify whether this is the case or not, and always include a scenario in which the development of wind energy (now and when scaling up) is not hindered.
NedZero hopes that the Ministry of Defense will read this view as an invitation to conduct further dialogue, and looks forward to any fruitful consultation.
Yours sincerely,
Paul van Egmond
Industry specialist on onshore wind, NedZero
