Representation by Nicholas Thorp
- Date submitted
- 26 January 2020
- Submitted by
- Members of the public/businesses
I endorse Relevant Representations by SASES, Friston Parish Council & Suffolk authorities, specifically objections to onshore proposals & suitability of land at Grove Wood, Friston to locate substations. As a Friston resident I object to 3 vast substations just 200 metres from nearest homes. DCO application fails to comply with SPR’s own “Target Buffer” of 250 metres from homes. Scottish Power Renewables (SPRs) proposals fail to achieve rudimental embedded mitigation. Even if a 250m buffer were achievable, this development would still be closer than the adopted industry model, substations at least 500 to 600 metres from homes. Substation Site Selection & Design - Questionable need for development - EA1N could & should have been via Bawdsey to Bramford cable and grid connection north of Ipswich. - Substation location at Grove Wood fails to ensure adequate safety to the adjacent community of Friston - Villagers’ homes, health and wellbeing. - Design principals focus on basic aesthetics, not on a ‘best engineered’, ‘low impact’ design to reduce overall size, visual impact and working noise emissions. - Unacceptable long-term visual impact, limited scope for effective screening due to confines and limitations of surrounding landscape. Planting proposals provide little effective screening even after 15-25 years. - Substations not bedded-into landscape, therefore the best possible screening and emitted noise reduction can never be achieved. - High long-term impact of change to the landscape at the substation site and permanent loss of 80+ acres of high-quality agricultural land. - National Grid substation should be an NSIP & DOC in its own right. It has not been properly consulted or scrutinised – Failure by developer SPR, National Grid but also planning processes. Flooding - Substation development could significantly increase flood risk to homes in Friston. - Proposed substation site sits directly over a ‘surface water’ flood path as identified by Environment Agency flood mapping. SPR have not accounted for changes to surface water flooding attributable to their own development. SPR’s Environmental Impact Assessment fails to provide necessary assurance’s on baseline flood risks caused by the development. - DCO suggests the National Grid substation may need to be raised to account for ‘potential to flood’, further evidence Grove Wood is unsuitable and unsafe. - SPR should provide an independent flood risk study concerning the proposed substation site and interaction with the Friston water course and storm drainage/ditching. Noise & Lighting - Construction noise issues substation site. - Working substation noise output - 34db LAeq5min limit is unacceptable given proximity to Friston and homes, especially in the evening where existing background noise is negligible. - No consideration for a tonal penalty, this does not comply with industry practice and is unacceptable due to proximity of homes. - Cumulative noise output of 3 working substations has not been assessed, the assertion a NG substation will have no measurable noise output is not credible. - Substation operational noise has the potential to be a constant background menace for those living close-by. Independent noise assessments must be modelled in order to prove SPRs figures. - Flood lighting and motion controlled lighting will be a anti-social menace to wildlife and people living close to onshore construction sites/cable route. Cable landing and cable route - Unsuitable cable landing zone, Thorpeness sand cliffs are fragile and exposed, vibration of cable drilling could cause cliff falls and promote onset of catastrophic coastal erosion. - Maps provided labelled wrongly, the cable corridor runs across Thorpeness common (ancient common land). - Cable route will close, divert and disrupt PRoW which are essential to the AONB and tourism. - A 64-metre-wide swathe of AONB will be trenched and damaged en-route to substation site 11km away. Environmental/Ecology - Plans do not show sufficient acknowledgement of or commitment to protect designated AONB landscape. - Coastal habitat of protected wildlife snakes, reptiles and Sandlings ecology damaged or destroyed. Cable trenching will kill many protected reptiles and snakes which live in burrows. - Substation site at Friston has bats, badgers and 2 nesting pairs of barn owls living on or close by, all protected species. Traffic & Transport - Small country lanes are not suitable for HGVs & sheer number of construction and ancillary traffic. - Traffic/road improvement measures show a lack of understanding or the commitment by SPR to address necessary road improvements. Tourism / Socio Economics - SPR suggests development will be +ve for the local economy. However, only a small number of permanent jobs will be created (miles away in Lowestoft). After construction there are no permanent local jobs as substations are automated. - DCO assessments do not account for the potential to damage the appeal of the AONB & coastal tourism or how they plan to address this. Cumulative Impact - Cumulative impact has not been assessed adequately between EA1N, EA2 and NG substations, cabling etc. Or in the mix with other energy proposals SZC (Sizewell C), Euro-connector’s & existing windfarm extensions. - National Grid incompetence assessing environmental and economic impact of connection offers or how they interact with one another and the communities & businesses that live & operate here. Nuclear Evacuation Zone ONR - SPR failed to consult with the appointed Emergency Planning Officer at Suffolk County Council and with the ONR regarding the Sizewell nuclear evacuation zone – If so the DCO has not been consulted for in accordance the Planning Act 2008.