Representation by SEAS (Suffolk Energy Action Solutions) (SEAS (Suffolk Energy Action Solutions))
- Date submitted
- 26 January 2020
- Submitted by
- Members of the public/businesses
To the Examining Panel, RE: SEAS Representation for both East Anglia One North and East Anglia Two We wish to object and challenge ScottishPower’s ill-conceived plans relating to East Anglia One North and East Anglia Two for the following reasons: 1. Alternative sites have not been fully considered An Environmental Statement (ES) must include a description of the reasonable alternatives studied by the applicant, which are relevant to the proposed development and an indication of the main reasons for the chosen option, taking into account the effects of the development on the environment. The ES does not consider or discuss the option of an offshore RingMain (ORM) despite there being documented discussions regarding this option which date back many months and which show that the Applicant has studied this alternative option. The Applicant has failed to mention the reasonable alternatives that it has considered. We are aware of the 2011 and 2015 reports on ORM and that SPR has studied these and previous reports, which identified potential by National Grid for synergies and cost efficiencies achieved from a co-ordinated offshore grid network. A workgroup was established to investigate issues and potential solutions. This included the East Anglia offshore wind developers working with NG and with input from Ofgem. The fact that the U.K. still has no national policy for offshore transmission infrastructure and that there is no evidence that NG and Ofgem have pursued such a holistic strategy is undermining the NSIP process and allowing a piecemeal and seemingly opportunistic and arbitrary approach to the choice of substation site to take place along the East Anglia coast, Friston is just one example of this. Other countries in the North Sea region including Holland, Denmark and Germany are working together to develop offshore transmission infrastructure solutions recognising the growing importance of offshore wind power. Since the U.K. 2011 report it is clear that significant advances have taken place in technology and commercial opportunities. The Applicant’s failure to work with NG, Ofgem and Government (BEIS in particular), to explore fully an ORM or platform hubs and artificial islands at sea, is judged unreasonable given the significant harm that will be suffered as a result of the proposed onshore development. This option cannot be reasonably considered without input from Ofgem, NG, Planning Inspectorates and Government or other Applicants. Our view is that the NSIP system is flawed, out-of-date and no longer appropriate for the development of a stream of at least seven energy transmission infrastructure projects that are required to meet the UK’s future energy needs. It does not consider any other alternative technologies, for example hydrogen, which are emerging and will provide opportunities to develop combined generation and grid solutions. Furthermore, why has Bramford been disregarded? And, other Brownfield sites such as Bradwell and others closer to the Thames Estuary for a hub landfall for a series of substations and interconnectors? Redacted documents have not provided any justification and cost alone is no longer sufficient basis for decision-making. What value is placed on the environment ? Our countryside is not renewable. Ecocide cannot be justified by these plans in the name of so- called green energy. Green energy is no longer green if these plans are accepted. 2. Cumulative impacts have not been properly assessed The Applicant has not used the standard quantitative assessment template formats to interrogate the possible adverse impacts of the onslaught of a minimum of seven energy projects. It is very difficult to determine the adequacy, transparency and robustness of these plans given the qualitative nature of the research and assessment. We challenge many aspects of these plans including the transport infrastructure at Orwell Bridge, A1094 small Victorian bridges and given the weight of traffic is already causing lorry jams at roundabouts, we believe that offshore transportation of construction materials is the only viable solution. Tourism is dependent on the tranquillity and unspoilt landscape of the region. This tourism will be eroded because visitors will find more attractive places to go. The environmental impact on AONB, rare habitats, Grove Wood air quality, Thorpeness coralline Cliffs, Minsmere and related unique wetlands, low heathlands, Sandlings and pilgrims’ pathways will lead to unnecessary destruction, and thus, we have to challenge these plans. Confirmation of the DCO cannot be established until a full and proper strategy and review of Government Policy takes place and we are calling for a halt to the DCO process in order that this review takes place at the earliest opportunity. 3. Permanent noise on Friston site The permanent low humming noise produced by harmoniser filters and CVS has not been fully assessed for a substation and inter connector site so close to residential homes in Friston. Benchmarking other case studies in the U.K., we have researched the permanent suffering and ill health caused by these low base humming noises which are continuous. The houses in Friston are very proximate to the infrastructure site ( some are within 30m). We do not think that the quantitative studies taken by SPR are adequate to draw their conclusions that the permanent noise is of moderate importance to most residents. We challenge this conclusion. 4. Rare habitats and unique low heathlands and wetlands are priceless How has SPR valued the rarity of these unique low heathlands and wetlands? They represent 1% of the planet’s total low heathlands combined with wetlands of this particular type. This coastline is known to be fragile in every sense. How do you assess this fragility and compensate for its loss? We do not believe that there can ever be adequate mitigation for something which is priceless. The pure red deer, the skylarks, the nightingales, the badgers, the particular bats and other creatures are under threat. They will not return after 12-15 years of mass industrialisation. How do you value that loss? 5. Social and economic decline We are not allowed to challenge this NSIP on the basis of social and economic decline. This is patently absurd. The NSIP system should be judged holistically, not just in terms of simple linear, commercial criteria. The jobs created in Lowestoft by the private energy companies are to be welcomed. Renewable energy is to be celebrated. Yet, if the cost of this putative green energy is loss of tourism leading to shop and restaurant closure, the decline in social well- being for the majority of residents who came to this area for tranquillity, unspoiled landscape and heritage, we cannot approve such irresponsible and linear commercial plans for the industrialisation of one of our most fragile coastlines in the U.K. Already, there is evidence of ill-health and sickness from worry about the threat hanging over many local communities. Your sincerely, Fiona Gilmore For and on behalf of SEAS Campaign