Representation by Paull Zisman
- Date submitted
- 26 January 2020
- Submitted by
- Members of the public/businesses
1 It is inappropriate that the village of Friston falls outside the 'onshore development area'. The Environmental Statement does not consider the impacts of traffic and transport and air quality from the construction of the substation on Friston. 2 The Scoping Opinion requires that the application provides a description of reasonable alternatives. The Environmental Statement does not consider or discuss the option of offshore transmission infrastructure. The 2011 report “Coordination in Offshore transmission – an assessment of regulatory, commercial and economic issues and options” commissioned by Ofgem noted: “Where significant development of offshore generation resources is undertaken, coordinated and integrated offshore transmission grids offer economic benefits versus individual point to point connections, interconnections and associated onshore reinforcements.” 3 East Anglia 3 was consented in 2017; why was consideration not given at this time to future need for an onshore substation for East Anglia One North and East Anglia Two, which were at pre-application stage? More detailed evidence as to why Bramford has now been disregarded should be provided. 4 SPR has not considered cumulative impacts associated with the Nautilus Interconnector. This is at the pre-application stage and is development reasonably likely to come forward. 5 The Cumulative Impact Assessment for air quality, noise and vibration and traffic and transport with Sizewell C are qualitative and not quantitative. This is not acceptable due to the significance of these potential aggregated impacts. 6 Cumulative impacts between East Anglia One North and East Anglia Two were assessed as being not significant. This is incorrect. It appears that this finding is based on the landfall and cable route only and has not taken the construction of the substation into account. 7 There are alternative locations for the substation and cable route that would significantly reduce transport and traffic related impacts. SPR failed to properly consider alternative locations in the early consultation phases. 8 The Environmental Statement fails to consider how construction traffic will get to the substation site. The information which is included is inconsistent and contradictory, in particular with regard to the B1121. 9 The onshore highways study area is incorrect as it does not include the B1121. 10 The Environmental Statement does not provide any detail about the construction of the permanent access road required to access the onshore substations. 11 SPR’s application does not consider adequately the severe negative economic impacts. The Suffolk Coast and Heaths AOBN supports over 4,650 jobs and delivers over £210 million total tourism value (Economic Impact of Tourism in the Suffolk Coast and Heaths AONB 2017). The Destination Management Organisation’s independent report concluded that the proposed National Strategic Infrastructure Projects (NSIP) in East Suffolk would reduce tourist revenues by £40 million annually. 12 Many people in the area lead a fragile economic existence, with multiple sources of employment such as working in shops and restaurants and cleaning and maintenance in holiday lets. In an area where there are few alternative jobs, many people’s lives will be decimated if the noise, dust and heavy construction traffic result in a downturn in tourism. 13 Aldeburgh Hospital does not have Accident and Emergency facilities. These are provided from Ipswich Hospital. Delays to ambulances caused by heavy construction traffic will cost lives. 14 The Secretary of State has indicated that an offshore ring main lends “itself to a consultation” and that it should be discussed further with the Minister of State, Kwasi Kwarteng. This is highly material to this planning application. The development consent order process cannot proceed in a meaningful way until this consultation has been carried out and any strategy in this area has been adopted by the Secretary of State. Similarly, any consultation to be carried out by the Minister would be rendered pointless if the applications for development consent orders are considered without any regard to the consultation.