Representation by Catherine Judith Pinnekamp
- Date submitted
- 25 January 2020
- Submitted by
- Members of the public/businesses
CUMULATIVE IMPACT • Sizewell C - DCO Application 2020? • National Grid Ventures Interconnectors • Nautilus - Public Consultations in 2020 • Eurolink - Plans to follow • Expansion of offshore windfarms • Galloper • Greater Gabbard HUMAN IMPACT • Vulnerable and ageing population • Uncertainty • Loss of footpaths and visual enjoyment • Loss of equity and financial implications • Quality of life damaged by noise and light pollution • Damage to air quality • Severance of village due to traffic impacts LANDSCAPE • Severe landscape and visual harm that cannot be mitigated. • Severs a substantial area of tranquil, open and deeply rural countryside. • Changes the character of Friston. • Highly questionable assumptions of mitigation planting. HERITAGE • Site is ringed by listed buildings – five grade II, two grade II* • Impact assessments underestimate the impact significantly plus: • setting – ignores National Guidance • cumulative impact • Visualisations/viewpoints are misleading • Landscape mitigation does very little to mitigate heritage impact SITE SELECTION • Defective process particularly with regard to National Grid works LAND USE • Substantial loss (83 acres) of Grade 2 and 3 agricultural land • Impact is understated LIGHT POLLUTION • During construction • 24 hour security lighting at construction consolidation sites • Task lighting during 24 hour construction periods...... • During operation • Security lighting possibly motion sensitive • Car park lighting possibly motion sensitive • For inspection/repair/maintenance • Impact understated SOCIO ECONOMIC – ONSHORE • No jobs from onshore development • Damage to tourism – DMO report not addressed – loss of jobs • No analysis of loss of “inward investment” – loss of jobs FLOOD RISK • The current village drainage infrastructure is inadequate. • SPR state clearly there is an increase in flood risk and sediment mobilisation due to the development. • But does not show that proposed mitigation measures are sufficient, feasible or achievable. • No assessment of the adequacy of the Friston Watercourse has been undertaken. • SPR take no proper account of surface water flooding. 2 • SPR propose two new retention ponds on the substation site but ignore the existing field drainage system, which will be removed. • These matters of environmental impact must be addressed prior to consent. FOOTPATHS & PUBLIC RIGHTS OF WAY • The footpath (FP6) running north from the village to Little Moor Farm will be permanently closed • This footpath is the historic parish boundary between Friston and Knodishall. • An alternative route is proposed to run alongside the edge of Grove Road, close to the substation site. This is a very long diversion and most unattractive to potential users, due to loss of tranquillity and landscape features. • 26 other Rights of Way along the cable route will be “temporally” closed or diverted for unspecified periods. ONSHORE ECOLOGY • Permanent removal of approx. 30 acres of wildlife habitat across the substation site. • This includes the permanent removal of four badger setts and several bat-roosting sites, together with hedgerows forming foraging routes. • There will be permanent effects on birds and wildlife due to light and noise pollution from the substations. • During the lengthy construction period all types of wildlife along the cable route will be disrupted and/or displaced. SUBSTATION DESIGN ISSUES • SPR have not listened to our requests to reduce the visual impact of their substations • Harmonic filters at 18m are the tallest items proposed, and were 21m until noise screening was removed by popular request (was this a good idea?) • Other wind farm substations have much lower profiles (e.g. Rampion substation in West Sussex has almost nothing above 8m - a ‘low impact design’) • Current SPR design principles only concerned with the visual appearance of building structures, not engineering elements. This is unacceptable. NOISE • 34dBLAeq5min reference level now proposed rather than 35dBLAeq15min, but currently applies only to SSR2 and SSR5 NEW, rather than all residential locations • Super-grid transformers and their cooling fans are noisy, but Harmonic Filters now identified as noisiest items (and tallest at 18m), and are now unscreened • SPR claim no ‘humming’ noise (‘Tonality’) but this will be disputed as it affects ‘Impact’ ratings • Without a ‘Tonality’ correction noise levels may be almost 3 x greater than at Bramford (+5dBA). • Impact of atmospheric effects is a further concern. • The community should demand no discernible noise from the substations inside or outside our buildings day or night, to be proven by measurement after construction, not just on paper TRAFFIC & TRANSPORT • Proposals include: • Changes to A12/A1094 junction (Friday Street) and A1094/B1069 junction Blackheath Corner • Pre-Construction access to the development and haul road at the junction of Church Road and Grove Road • Scottish Power will only monitor passage of Heavy Goods Vehicles • What routes will all other traffic take and the relative risks • A1094 to Aldeburgh 3 • B1069 Blackheath Corner to Leiston • B1122 Aldeburgh to Leiston • Friston most at risk – B1121 Aldeburgh to Saxmundham Road; • Mill Road almost single track by-road no pedestrian pavement; • Grove Road is narrow, twisting and turning with no pedestrian pavement already a heavily used cut-through to Knodishall, Saxmundham and Leiston • Key Safety Issues • Traffic flows and speeds. • Drivers seek alternative routes and lanes become “rat-runs” • Impact on emergency vehicles access and timings. • Protection for walkers and cyclists. • Sizewell Evacuation Plan CABLE CORRIDOR ISSUES • Landfall at Thorpeness: fragility of the cliffs • A 9Km long cable route impacting numerous receptors including TPO (SCDC/87/00030) • The Aldeburgh Road “pinch point” cable crossing : no evidence that SPR has properly considered the feasibility of other crossing points such as further north near Thorpe Road • Destruction of large area of woodland both sides of the Aldeburgh Road contrary to SPR’s Cable Route Design Principle : to “minimise interaction with mature woodland“ • Ecology and ornithology surveys outside AONB are not complete • Cable corridor is sited unacceptably close to residential properties • Cable corridor sited much closer (too close) to some residential titles than previously specified • Concern that the construction noise assessment and impact on residential titles has been underestimated – no commitment to mitigate noise, dust etc • Landfall and haul road CCS’s : SPR did not consult on siting of the latter; light pollution issues • No commitment to restore woodland and no commitment to remove all haul roads and return land to as before • Assessment of and management of construction traffic impact (highway and haul roads) is also suspect • Flood risk at River Hundred crossing during construction not addressed • No cumulative assessment with other forthcoming projects and SPR’s plans not to "sterilize" the cable route for other projects to build cable corridors alongside EA1N/EA2 No consideration of OFfshore Ring Main