AR6 Contract Awards to Hornsea Project 3 Under Permitted Reduction Scheme
Dear Low Carbon Contracts Company Limited,
Orsted’s Hornsea Project Three was awarded CfD contracts with a total capacity of 1,080MW. However, the original capacity of Hornsea Three awarded in AR4 was 2,852MW and 1,080MW represents 37.9% of the original capacity. When the AR4 contracts were awarded, the limit for permitted reductions was supposed to be 25% of the original capacity (see contract condition 6.2 on p82 of the AR4 contract: https://assets.publishing.service.gov.uk... ).
On the face of it, Hornsea Project 3 was awarded contracts in AR6 above the limit for Permitted Reductions allowed under its original AR4 contract. As I understand it, LCCC is the body that monitors compliance with contractual requirements following award of contracts.
I would therefore like to request:
1) Transcripts of all forms of contact (including but not limited to meetings, emails, electronic messages and telephone calls) to and from LCCC regarding the award of the contracts under AR6 to Hornsea Project 3.
2) Copies of all internal working papers regarding the checking and approval of compliance of Hornsea Project 3 with the contracts awarded under AR4 and AR6.
Thank you for your assistance.
Yours faithfully,
David Turver
**** This is an automated response from Low Carbon Contracts Company*****
Hello,
Thank you for submitting your query. We aim to respond to you by
12/02/2025.
If you need to contact us further in relation to your query, please reply
to this email.
Please note that we retain your contact details for future reference and
update them accordingly when you contact us again. Further information on
how the Companies process personal information is set out in the
Companies’ Privacy Notice available at:
[1]https://www.lowcarboncontracts.uk/index....
Best wishes,
Low Carbon Contracts Company
Short description:
Freedom of Information request - AR6 Contract Awards to Hornsea Project 3
Under Permitted Reduction Scheme
Description:
External Email! Please be cautious. DO NOT click links or open attachments
unless you recognise the sender and know the content is safe. If you are
unsure if this email is genuine, please forward it to [email address]
Dear Low Carbon Contracts Company Limited,
Orsted’s Hornsea Project Three was awarded CfD contracts with a total
capacity of 1,080MW. However, the original capacity of Hornsea Three
awarded in AR4 was 2,852MW and 1,080MW represents 37.9% of the original
capacity. When the AR4 contracts were awarded, the limit for permitted
reductions was supposed to be 25% of the original capacity (see contract
condition 6.2 on p82 of the AR4 contract:
https://assets.publishing.service.gov.uk...
).
On the face of it, Hornsea Project 3 was awarded contracts in AR6 above
the limit for Permitted Reductions allowed under its original AR4
contract. As I understand it, LCCC is the body that monitors compliance
with contractual requirements following award of contracts.
I would therefore like to request:
1) Transcripts of all forms of contact (including but not limited to
meetings, emails, electronic messages and telephone calls) to and from
LCCC regarding the award of the contracts under AR6 to Hornsea Project 3.
2) Copies of all internal working papers regarding the checking and
approval of compliance of Hornsea Project 3 with the contracts awarded
under AR4 and AR6.
Thank you for your assistance.
Yours faithfully,
David Turver
-------------------------------------------------------------------
Please use this email address for all replies to this request:
[FOI #1233057 email]
Is [LCCC request email] the wrong address for Freedom of Information
requests to Low Carbon Contracts Company Limited? If so, please contact us
using this form:
https://www.whatdotheyknow.com/change_re...
Disclaimer: This message and any reply that you make will be published on
the internet. Our privacy and copyright policies:
https://www.whatdotheyknow.com/help/offi...
For more detailed guidance on safely disclosing information, read the
latest advice from the ICO:
https://www.whatdotheyknow.com/help/ico-...
https://www.whatdotheyknow.com/help/ico-...
Please note that in some cases publication of requests and responses will
be delayed.
If you find this service useful as an FOI officer, please ask your web
manager to link to us from your organisation's FOI page.
-------------------------------------------------------------------
Ref:MSG0193008
References
Visible links
1. https://www.lowcarboncontracts.uk/index....
Hello,
Further to your recent query, please can you provide the information
outlined below:
05/02/2025 12:46:42 GMT - Madison Webb (Work notes) Dear David, Thank you
for submitting your FOI query. I can confirm this has been passed onto our
internal team and we will endeavor to have a response for you in 19
working days. Kind regards, LCCC
========
Please reply directly to this email and maintain the query number included
in the subject line of this email.
Best wishes,
Low Carbon Contracts Company
Short description:
Freedom of Information request - AR6 Contract Awards to Hornsea Project 3
Under Permitted Reduction Scheme
Description:
External Email! Please be cautious. DO NOT click links or open attachments
unless you recognise the sender and know the content is safe. If you are
unsure if this email is genuine, please forward it to [email address]
Dear Low Carbon Contracts Company Limited,
Orsted’s Hornsea Project Three was awarded CfD contracts with a total
capacity of 1,080MW. However, the original capacity of Hornsea Three
awarded in AR4 was 2,852MW and 1,080MW represents 37.9% of the original
capacity. When the AR4 contracts were awarded, the limit for permitted
reductions was supposed to be 25% of the original capacity (see contract
condition 6.2 on p82 of the AR4 contract:
https://assets.publishing.service.gov.uk...
).
On the face of it, Hornsea Project 3 was awarded contracts in AR6 above
the limit for Permitted Reductions allowed under its original AR4
contract. As I understand it, LCCC is the body that monitors compliance
with contractual requirements following award of contracts.
I would therefore like to request:
1) Transcripts of all forms of contact (including but not limited to
meetings, emails, electronic messages and telephone calls) to and from
LCCC regarding the award of the contracts under AR6 to Hornsea Project 3.
2) Copies of all internal working papers regarding the checking and
approval of compliance of Hornsea Project 3 with the contracts awarded
under AR4 and AR6.
Thank you for your assistance.
Yours faithfully,
David Turver
-------------------------------------------------------------------
Please use this email address for all replies to this request:
[FOI #1233057 email]
Is [LCCC request email] the wrong address for Freedom of Information
requests to Low Carbon Contracts Company Limited? If so, please contact us
using this form:
https://www.whatdotheyknow.com/change_re...
Disclaimer: This message and any reply that you make will be published on
the internet. Our privacy and copyright policies:
https://www.whatdotheyknow.com/help/offi...
For more detailed guidance on safely disclosing information, read the
latest advice from the ICO:
https://www.whatdotheyknow.com/help/ico-...
https://www.whatdotheyknow.com/help/ico-...
Please note that in some cases publication of requests and responses will
be delayed.
If you find this service useful as an FOI officer, please ask your web
manager to link to us from your organisation's FOI page.
-------------------------------------------------------------------
Ref:MSG0193153
Dear David,
Thank you for submitting your request. Please view the response below:
1) Transcripts of all forms of contact (including but not limited to
meetings, emails, electronic messages and telephone calls) to and from
LCCC regarding the award of the contracts under AR6 to Hornsea Project 3.
We do not hold this information. The Low Carbon Contracts Company Ltd
(LCCC) is the designated counterparty to the Contracts for Difference
(CfD) scheme. LCCC plays no role in the allocation of CfDs and is
required by legislation to offer CfDs to successful applicants on the
standard terms published by the Department for Energy Security and Net
Zero (DESNZ) and notified to it by the National Energy System Operator
(NESO).
2) Copies of all internal working papers regarding the checking and
approval of compliance of Hornsea Project 3 with the contracts awarded
under AR4 and AR6.
We do hold this information. However, we consider that the exemption set
out in Regulation 12(4)(e) of the Environmental Information Regulations
2004 (internal communications) is engaged in relation to this document. We
can, however, confirm that the AR4 Hornsea 3 project reduced its Initial
Installed Capacity Estimate by 25% prior to the Milestone Delivery Date in
line with the terms of the AR4 CfD.
If you are dissatisfied with the handling of your request, you have the
right to ask for an internal review and the right to make representations
to us in writing. Internal review requests should be submitted within two
months of the date of receipt of this response and should be addressed to:
Head of Legal, at Low Carbon Contracts Company Ltd, 10 South Colonnade,
Canary Wharf, London E14 4PU, and emailed to [1][email address].
If you are not content with the outcome of the internal review, you have
the right to apply directly to the Information Commissioner for a
decision. The Information Commissioner can be contacted at: Information
Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9
5AF, and more information can be found at [2]https://ico.org.uk/.
Kind regards,
LCCC
Ref:MSG0194305
References
Visible links
1. mailto:[email address]
mailto:[email%20address]
2. https://ico.org.uk/
Dear Low Carbon Contracts Company Limited,
Please pass this on to the person who conducts Freedom of Information reviews.
I am writing to request an internal review of Low Carbon Contracts Company Limited's handling of my FOI request 'AR6 Contract Awards to Hornsea Project 3 Under Permitted Reduction Scheme'.
I note that you have refused my request for copies of papers relating to the ongoing compliance of Hornsea Project 3 with the terms of its AR4 and AR6 contracts. The grounds you have used are section 12(4)(e) of the Environmental Regulations. On the face of it, Hornsea Project 3 is in breach the Permitted Reduction rules because it received contracts in AR6 for 37.9% of the original capacity awarded in AR4, when the permitted reduction is just 25%. You confirm that Hornsea has been granted at 25% reduction. It therefore remains a mystery why it was awarded contracts in excess of this limit in AR6 and remain in compliance with its contracts.
I believe that it is in the public interest to understand whether and how Hornsea Project 3 remains in compliance with its AR4 and AR6 contracts. I contend that the public interest should override concerns about the internal free-exchange of ideas within LCCC and therefore request an internal review of your decision.
A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/a...
Yours faithfully,
David Turver
**** This is an automated response from Low Carbon Contracts Company*****
Hello,
Thank you for submitting your query. We aim to respond to you by
28/02/2025.
If you need to contact us further in relation to your query, please reply
to this email.
Please note that we retain your contact details for future reference and
update them accordingly when you contact us again. Further information on
how the Companies process personal information is set out in the
Companies’ Privacy Notice available at:
[1]https://www.lowcarboncontracts.uk/index....
Best wishes,
Low Carbon Contracts Company
Short description:
Internal review of Freedom of Information request - AR6 Contract Awards to
Hornsea Project 3 Under Permitted Reduction Scheme
Description:
External Email! Please be cautious. DO NOT click links or open attachments
unless you recognise the sender and know the content is safe. If you are
unsure if this email is genuine, please forward it to [email address]
Dear Low Carbon Contracts Company Limited,
Please pass this on to the person who conducts Freedom of Information
reviews.
I am writing to request an internal review of Low Carbon Contracts Company
Limited's handling of my FOI request 'AR6 Contract Awards to Hornsea
Project 3 Under Permitted Reduction Scheme'.
I note that you have refused my request for copies of papers relating to
the ongoing compliance of Hornsea Project 3 with the terms of its AR4 and
AR6 contracts. The grounds you have used are section 12(4)(e) of the
Environmental Regulations. On the face of it, Hornsea Project 3 is in
breach the Permitted Reduction rules because it received contracts in AR6
for 37.9% of the original capacity awarded in AR4, when the permitted
reduction is just 25%. You confirm that Hornsea has been granted at 25%
reduction. It therefore remains a mystery why it was awarded contracts in
excess of this limit in AR6 and remain in compliance with its contracts.
I believe that it is in the public interest to understand whether and how
Hornsea Project 3 remains in compliance with its AR4 and AR6 contracts. I
contend that the public interest should override concerns about the
internal free-exchange of ideas within LCCC and therefore request an
internal review of your decision.
A full history of my FOI request and all correspondence is available on
the Internet at this address:
https://www.whatdotheyknow.com/request/a...
Yours faithfully,
David Turver
-------------------------------------------------------------------
Please use this email address for all replies to this request:
[FOI #1233057 email]
Disclaimer: This message and any reply that you make will be published on
the internet. Our privacy and copyright policies:
https://www.whatdotheyknow.com/help/offi...
For more detailed guidance on safely disclosing information, read the
latest advice from the ICO:
https://www.whatdotheyknow.com/help/ico-...
https://www.whatdotheyknow.com/help/ico-...
Please note that in some cases publication of requests and responses will
be delayed.
If you find this service useful as an FOI officer, please ask your web
manager to link to us from your organisation's FOI page.
-------------------------------------------------------------------
Ref:MSG0194429
References
Visible links
1. https://www.lowcarboncontracts.uk/index....
Hello,
Further to your recent query, please can you provide the information
outlined below:
21/02/2025 10:29:26 GMT - Madison Webb (Work notes) Dear David, Thank you
for reaching out to LCCC. I can confirm your request for an internal
review of an FOI request has been passed on to our legal team and you
shall receive a response in 19 working days. Kind regards, Madison
========
Please reply directly to this email and maintain the query number included
in the subject line of this email.
Best wishes,
Low Carbon Contracts Company
Short description:
Internal review of Freedom of Information request - AR6 Contract Awards to
Hornsea Project 3 Under Permitted Reduction Scheme
Description:
External Email! Please be cautious. DO NOT click links or open attachments
unless you recognise the sender and know the content is safe. If you are
unsure if this email is genuine, please forward it to [email address]
Dear Low Carbon Contracts Company Limited,
Please pass this on to the person who conducts Freedom of Information
reviews.
I am writing to request an internal review of Low Carbon Contracts Company
Limited's handling of my FOI request 'AR6 Contract Awards to Hornsea
Project 3 Under Permitted Reduction Scheme'.
I note that you have refused my request for copies of papers relating to
the ongoing compliance of Hornsea Project 3 with the terms of its AR4 and
AR6 contracts. The grounds you have used are section 12(4)(e) of the
Environmental Regulations. On the face of it, Hornsea Project 3 is in
breach the Permitted Reduction rules because it received contracts in AR6
for 37.9% of the original capacity awarded in AR4, when the permitted
reduction is just 25%. You confirm that Hornsea has been granted at 25%
reduction. It therefore remains a mystery why it was awarded contracts in
excess of this limit in AR6 and remain in compliance with its contracts.
I believe that it is in the public interest to understand whether and how
Hornsea Project 3 remains in compliance with its AR4 and AR6 contracts. I
contend that the public interest should override concerns about the
internal free-exchange of ideas within LCCC and therefore request an
internal review of your decision.
A full history of my FOI request and all correspondence is available on
the Internet at this address:
https://www.whatdotheyknow.com/request/a...
Yours faithfully,
David Turver
-------------------------------------------------------------------
Please use this email address for all replies to this request:
[FOI #1233057 email]
Disclaimer: This message and any reply that you make will be published on
the internet. Our privacy and copyright policies:
https://www.whatdotheyknow.com/help/offi...
For more detailed guidance on safely disclosing information, read the
latest advice from the ICO:
https://www.whatdotheyknow.com/help/ico-...
https://www.whatdotheyknow.com/help/ico-...
Please note that in some cases publication of requests and responses will
be delayed.
If you find this service useful as an FOI officer, please ask your web
manager to link to us from your organisation's FOI page.
-------------------------------------------------------------------
Ref:MSG0194515
Dear Mr Turver
I refer to your request for an internal review of Low Carbon Contracts
Company’s (LCCC’s) handling of your FOI request ‘AR6 Contract Awards to
Hornsea 3 Under Permitted Reduction Scheme’ dated 21 February 2025. Your
request for information sought:
(1) Transcripts of all forms of contact (including but not limited to
meetings, emails, electronic messages and telephone calls) to and from
LCCC regarding the award of the contracts under AR6 to Hornsea Project 3;
and
(2) Copies of all internal working papers regarding the checking and
approval of compliance of Hornsea Project 3 with the contracts awarded
under AR4 and AR6.
Our response to your request confirmed that LCCC does not hold information
in relation to item (1) of your request as LCCC plays no role in the
allocation process for CfDs other than being required under the relevant
regulations to make offers of CfDs to successful applicants notified to it
by the National Energy System Operator.
In relation to item (2) of your request, our response confirmed that we do
hold information in relation to the ongoing compliance of Hornsea 3
offshore windfarm project with the contracts awarded under AR4 and AR6 but
that we considered these documents fell under the exception in Regulation
12(4)(e) of the Environmental Information Regulations (internal
communications). Having reviewed the documents I consider that this
exception continues to be engaged and the public interest in maintaining
the exception outweighs the public interest in disclosing the information.
I reach this conclusion for principally two reasons:
(a) The CfD is a private law contract and it is important for the
integrity of the scheme that LCCC, as the designated CfD counterparty
under the Energy Act 2013, is able to monitor, evaluate and discuss
internally ongoing compliance with its CfDs. Not being able to do this in
a confidential manner would adversely affect LCCC’s ability to carry out
its regulatory and contractual obligations.
(b) These documents do not require to be disclosed in order for your
question to be answered (see further below).
Having reviewed your request, it appears that you are particularly
interested in whether Hornsea 3 is in breach of the 25% limit on permitted
reductions in its AR4 Contract for Difference. Our response to your
request on 18 February 2025 confirmed that Hornsea 3’s permitted reduction
was within the 25% limit, however, by way of further assistance on this
question I refer you to our public schemes register that clearly sets out
to extent of the permitted reduction for this project, along with other
project specific information: see link [1]Schemes Register and relevant
screen shot below.
The register confirms that this particular project elected to reduce its
initial installed capacity by 705.9MW which equates to a reduction of
24.75%.
I trust this information is helpful to you. If you are still dissatisfied
after our internal review, you can complain to the Information
Commissioner’s Office (ICO). You should make complaints to the ICO within
six weeks of receiving the outcome of an internal review. The easiest way
to lodge a complaint is through their
website: [2]www.ico.org.uk/foicomplaints.
Regards
Robin Woolnough
Head of Legal
Low Carbon Contracts Company
Ref:MSG0196335
References
Visible links
1. https://eur01.safelinks.protection.outlo...
https://eur01.safelinks.protection.outlo...
2. https://eur01.safelinks.protection.outlo...
https://eur01.safelinks.protection.outlo...
Hello,
Further to your recent query, please can you provide the information
outlined below:
14/03/2025 11:06:05 GMT - Madison Webb (Work notes) Dear David, I hope
this email finds you well. I have just received confirmation that my
colleague, Robin Woolnough has reached out to you concerning your request.
If you have any issues receiving the response, please do not hesitate to
get in touch and I will be happy to assist. Kind regards, Madison
========
Please reply directly to this email and maintain the query number included
in the subject line of this email.
Best wishes,
Low Carbon Contracts Company
Short description:
Internal review of Freedom of Information request - AR6 Contract Awards to
Hornsea Project 3 Under Permitted Reduction Scheme
Description:
External Email! Please be cautious. DO NOT click links or open attachments
unless you recognise the sender and know the content is safe. If you are
unsure if this email is genuine, please forward it to [email address]
Dear Low Carbon Contracts Company Limited,
Please pass this on to the person who conducts Freedom of Information
reviews.
I am writing to request an internal review of Low Carbon Contracts Company
Limited's handling of my FOI request 'AR6 Contract Awards to Hornsea
Project 3 Under Permitted Reduction Scheme'.
I note that you have refused my request for copies of papers relating to
the ongoing compliance of Hornsea Project 3 with the terms of its AR4 and
AR6 contracts. The grounds you have used are section 12(4)(e) of the
Environmental Regulations. On the face of it, Hornsea Project 3 is in
breach the Permitted Reduction rules because it received contracts in AR6
for 37.9% of the original capacity awarded in AR4, when the permitted
reduction is just 25%. You confirm that Hornsea has been granted at 25%
reduction. It therefore remains a mystery why it was awarded contracts in
excess of this limit in AR6 and remain in compliance with its contracts.
I believe that it is in the public interest to understand whether and how
Hornsea Project 3 remains in compliance with its AR4 and AR6 contracts. I
contend that the public interest should override concerns about the
internal free-exchange of ideas within LCCC and therefore request an
internal review of your decision.
A full history of my FOI request and all correspondence is available on
the Internet at this address:
https://www.whatdotheyknow.com/request/a...
Yours faithfully,
David Turver
-------------------------------------------------------------------
Please use this email address for all replies to this request:
[FOI #1233057 email]
Disclaimer: This message and any reply that you make will be published on
the internet. Our privacy and copyright policies:
https://www.whatdotheyknow.com/help/offi...
For more detailed guidance on safely disclosing information, read the
latest advice from the ICO:
https://www.whatdotheyknow.com/help/ico-...
https://www.whatdotheyknow.com/help/ico-...
Please note that in some cases publication of requests and responses will
be delayed.
If you find this service useful as an FOI officer, please ask your web
manager to link to us from your organisation's FOI page.
-------------------------------------------------------------------
Ref:MSG0196336
Dear Low Carbon Contracts Company Limited,
Thank you for your reply and subsequent follow up. I note that the original AR4 Hornsea Project 3 has been allowed a 25% reduction in capacity. However, this does not explain why and how it was granted 3 contracts under the AR6 Permitted reduction scheme totalling 37.9%of the original capacity. In effect the project now has contracts for more than the original capacity of the project.
I am not satisfied with your answer because I believe it is in the public interest to understand why and how the contracts were awarded and the rules apparently broken. Consumers will be paying more for their energy and other offshore wind farms may well have been disadvantaged as a result.
Consequently, I have referred this matter to the ICO.
Yours faithfully,
David Turver
We work to defend the right to FOI for everyone
Help us protect your right to hold public authorities to account. Donate and support our work.
Donate Now