Representation by William Halford
- Date submitted
- 23 January 2020
- Submitted by
- Members of the public/businesses
RE: East Anglia ONE North The headings below refer to National Policy Statements (NPS) for Overarching Energy (EN-1), NPS for Renewable Energy (EN-3) and NPS for Electricity Networks (EN-5). • I support the Relevant Representations being submitted by SASES and Friston Parish Council. Please consider my further objections to onshore components of this application for the following reasons. • The project will have great adverse environmental, social and economic impacts at local level, including long term and cumulative adverse effects. There also is a scarcity of measures to avoid, reduce or compensate for adverse effects (EN-1, 4.1.3 and 4.1.4) • I live at [Redacted]. Our primary concerns are with the impact on our lives of the Applicant having positioned the cable corridor unnecessarily close to our residential titles (house and garden) and also those of neighbouring residents in Aldeburgh Road and in Fitches Lane and the proposed destruction of a large area of attractive veteran woodland very close by on both sides of Aldeburgh Road, Aldringham. • My concerns relate to the Construction phases through to eventual post project Landscape Restoration. N.B. it is quite possible that construction of EA1N / EA2 will last up to a decade, depending on the two projects' eventual phasing and timetable if consented. 1. Landscape and visual amenity (EN-1, 1.7.2 and 5.9.6) 1.1 Site Selection – Substations • Applicant’s survey bias: The biased design of two questions in SPR’s Consultation Phase 2 Feedback Form was a critical factor in the Applicant’s flawed justification for its proposal to construct a Substations zone to the west of Aldeburgh Road, Aldringham. 1.2 Site Selection – Cable corridor • As a consequence of the flawed selection of a Grid connection at Friston, the DCO specifies a 9Km long cable corridor impacting numerous receptors including residential titles and Area Tree Preservation Order PO (SCDC/87/00030). • The proposed cabling/ haul road routes lie across the meadow at the bottom of our wooded garden, on the eastern side of the River Hundred. This meadow is a central feature of the (extant) “Aldringham R. Hundred Special Landscape Area (SLA)”, as designated by Suffolk Coastal District Council. • The Applicant proposes to position its cable corridors much closer to residential titles than previously specified, at a distance of only 25 metres at the closest point to our rear garden at Riverwood, 70 metres at the furthest. • DCO 4.9.2.2 Constraints Mapping and Engineering Feasibility, 171 states "Routeing across the woodland (and identified removal of trees) to the west of Aldeburgh Road as this is the only identified location where the cable route can cross Aldeburgh Road". 4.9.1.3.4 States at 146 that: "Following an engineering feasibility review, it was deemed feasible to cross Aldeburgh Road if woodland was removed immediately west of Aldeburgh Road, north of Fitches Lane." • We can find no evidence that the Applicant has properly considered the feasibility of other crossing points. No justification has been offered for its decision to destroy such a large area of woodland both sides of the Aldeburgh Road, Aldringham, contrary to its stated Cable Route Design Principle as listed in 4.9.1.2: "Minimise interaction with mature woodland". • The route proposed for the cable corridor crossing at Aldeburgh Road, Aldringham is sited unacceptably close to residential properties in Fitches Lane (only 5 metres from Fitches Lane), Gipsy Lane and in Aldeburgh Road. The southern boundary of Aldringham Court's Grounds is situated 46 metres north of Fitches Lane. The Applicant proposes a reduced width cable corridor (16 metres wide) north of Fitches Lane (or 32 metres wide should both EA1N and EA2 be consented). The southern boundary of the cable corridor Order Limit should have been sited at least 30 metres north of Fitches Lane (14 metres worse case if both projects are consented), thereby protecting a large area of woodland. • No justification has been offered for the Applicant's decision to deviate in a southerly direction from a straight line bearing drawn between the proposed Aldeburgh Road crossing at Access Id 5/6 and Thorpe Road at Access Id 3/ 4 (Cable Sections 3b and 2). That decision seems to have led to the cable corridor being so very close to our back garden. • The Applicant has failed to propose any mitigation measures for the protection of residents so close to the Cable Corridor to counter the negative impact of landscape, noise, dust and of artificial light during construction. 2. Cumulative negative effects and the extent of clustering of new energy infrastructure (EN-1, 1.7.3 and 4.2.5) • EA1N with EA2: a devastating 64 metres wide scar on land from Thorpeness to Friston, virtually the entire woodland landscape to be felled at Aldringham, Aldeburgh Road crossing point. • EA1N and EA2 with Sizewell C: the necessary assessment of cumulative impact has not been provided • EA1N and EA2 with other forthcoming NSIP Energy projects (Nautilus, EuroLink, Greater Gabbard extension, Galloper extension): Developers may well wish to run their cable corridors alongside EA1N / EA2. Those projects have not yet been formally scoped. Planning Inspectorate's insistence that the Applicant must not "sterilize" the cable route for other projects is evidence that regardless of the Applicant's refusal to take other Applicants' projects into account, PINS does appreciate that there are issue of Cumulative Impact along the onshore cable route. 3. Alternatives – an indication of main reasons for applicant’s choice, taking account of environmental, social and economic effects (EN-1, 4.4.2) • The Applicant has not included sufficient information in its ES on the main alternatives he has studied, as he is obliged to. • A notable omission is any satisfactory explanation as to why the Applicant moved landfall and Grid Connection for this project from Bawdsey to the “Leiston area”, through a post-consent “non-material change” to East Anglia ONE and without taking into account the environmental, social and economic effects of that decision as required by EN-1, 4.4.2. 4. Grid connection (EN-1, 4.9) • National Grid has assigned a new Grid connection in “the Leiston Area” for EA1N and EA2. It has allocated the same connection to National Grid Ventures for its forthcoming Nautilus and EuroLink Interconnector projects. • There has been no consultation regarding that decision, neither with key stakeholders nor with the general public. Only following repeated requests has National Grid released heavily redacted CION documents. These do not reveal quantified reasons for a connection at Friston or nearby. • Does PINS have the opportunity through EA1N and EA2 to consider the cumulative impact of having a multi-connection National Grid Substation located at a new Friston energy complex? 5. Health (EN-1, 4.13) • The cumulative impact during construction of noise, traffic, air pollution and dust on our lives and mental health at Riverwood would be highly damaging, [Redacted]. • The Applicant’s design does not address the need for EMF shielding for pedestrians walking along the roadside path near Gipsy Lane directly above High Voltage cables. (EN-5, 2.10.12) 6. Air quality and emissions (EN-1, 5.2) • The IAQM guidance (IAQM 2014) states that a Detailed Assessment is required where there are human receptors within 350m of the site boundary and/or within 50m of the route(s) used by construction vehicles on the public highway, up to 500m from the site entrance(s). • The Applicant has not provided an assessment of the inevitably unacceptable impact on residences at Fitches Lane and Gipsy Lane of Construction Phase dust and fine particulate matter or HGV emissions from vehicles crossing or turning at B1122 accesses 5 and 6. • The Applicant has not provided an assessment of Construction Phase dust and fine particulate matter on our residential title (garden and house) [Redacted]. We note that top soil at the East Suffolk Sandlings has the finest granularity in the UK and is thus most likely to cause nuisance to human receptors. 7. Biodiversity, Woodland and veteran trees (EN-1, 5.3 and 5.3.14) • The Applicant has not been prepared to commit to replanting the areas of woodland north of Fitches Lane and east of Aldeburgh Road that are to be removed to facilitate construction of haul roads and other (non-cabling) purposes. • No account has been taken of the prevalence of nightingales and rare glow worms along the cable route from Aldringham through to Fitches Wood. • A large mature oak tree at map coordinates 52.1884110 N 1.5796390 E lies at centre of proposed path for cable corridor at Aldringham but is not identifiable as a Target Note Reference in the Environmental Survey. • Contrary to 175(c) of National Planning Policy Framework the Applicant does not seem to have proposed a “compensation strategy” for the loss of large number of veteran trees, both sides of Aldeburgh Road, Aldringham. 8. Dust, odour, artificial light, smoke (EN-1, 5.3.14) • The Applicant acknowledges that this rural area of East Suffolk is noted for its dark skies. • Artificial lighting for security and other purposes is not acceptable. The Applicant must be required to use alternative modern methods (for example infra red devices) for securing the construction sites including Cable Corridor CCS areas. 9. Noise and vibration (EN-1 5.11) Construction Noise (Cable Corridor) • The Applicant has failed to satisfactorily demonstrate that it has addressed how the additional noise generated during construction would relate to the existing sound environment and the effect of noise on wildlife. • Residents living close to the proposed cable route and haul roads must be able to continue to enjoy their homes and gardens during the construction period without perceptible noise intrusion. • The Applicant has refused to publish noise contours for cable corridor construction. • The Noise Monitoring Survey Sensitive Receptor Location CCR9 was set incorrectly on the west side of the sensitive receptor at [Redacted], though the main source of construction noise would be from cable corridor which is on the east side. • The Applicant’s actual baseline sound levels for CCR9 were measured on the busy Aldeburgh Road, not at the coordinates it specified, thereby invalidating the Base Level sound measurements for CCR9. • A British Standard 5228 ABC Method was adopted for categorising receptors. It states that CCR9 is a Category A receptor and predicts construction noise at CCR9 at 54.6 dBA (Daytime and Weekends). According to my calculations using the Applicant’s base data, this is a gross underestimate. • I estimate that ‘Construction Noise Impact Magnitude’ at all places east side of the house would be classified according to BS5228 as ‘HIGH IMPACT’, Impact Significance : ‘MAJOR’ (Day time and Saturday working), not ‘NO IMPACT’, Impact Significance : ‘NEGLIGIBLE/ MINOR’ as stated by the Applicant. • The Applicant has not complied with our request at Consultation Phase 4 that mitigation measures must be implemented for noise impacting on Riverwood, should the cable route be built on the route now specified. The Applicant must be required to provide noise and visual mitigation measures along that length of the Cable Corridor that effectively reduce Sound Pressure at all parts of the residential title down to at least 65 dBA (assuming BS5228 recommendation is adopted) and that meet the appropriate EU standards for sound mitigation in residential areas. 10. Socio-economic (EN-1 5.12) • The Cable Corridor route from landfall at Thorpeness through to Friston contains 26 Public Rights of Way, many across Suffolk Coast & Heaths AONB. This small area of heritage coast is probably unique in the whole of Suffolk in having so many footpaths and bridleways in such a small area of countryside. They are used by local people and visitors to the area, being a major element in the attractiveness of the area as a holiday destination. • The many closures and "temporary" diversions proposed are further reason that the cable route chosen by the Applicant is not acceptable. 11. Traffic and Transport (EN-1 5.13) • A comprehensive Transport Management Plan is required taking account of the cumulative impact of EA1N with EA2 and with the EDF Sizewell C project. . • The Applicant must be required to specify and implement effective control, monitoring and enforcement mechanisms to ensure that contractors comply with the access routes specified for each section of the cable route. • The Applicant states an intention to build Haul Roads along the cable corridor for use by HGV’s and other traffic instead of the existing B-classification roads. That proposal is not explained or quantified in the DCO with any clarity. • I am concerned by the prospect of large numbers of such vehicles using a new haul road between Access Points 4 and 5 in Aldringham. These access points are in Aldringham village not as the Applicant states “south of Aldringham”. This haul road will be as close as 25 – 70 metres distance from our garden, probably much closer to residents Fitches Lane and Aldeburgh Road. The noise, dust and noxious fumes generated will be unacceptable. • HGV’s should be required to use the existing roads which already carry HGV’s, except when delivering to a particular section of the cable route. • The Applicant’s difficulties in making a decision on whether crossing points or road access at Access points Id 5 and Id 6 is indicative that the chosen Aldeburgh Road crossing point is not appropriate. • The Applicant must be required on completion to remove all Cable Route haul roads and to restore the land to its former state prior to their construction. END