Representation by Sybella Zisman
- Date submitted
- 26 January 2020
- Submitted by
- Members of the public/businesses
1 The 'onshore development area' is defined within the NTS is inadequate as it does not detail the road network (in particular the B1121) required to access the proposed onshore substation(s) or the village of Friston which is adjacent to the onshore substation(s). The exclusion of the B1121 and Friston means that the Environmental Statement does not consider appropriately the impacts of traffic and transport arising from the construction of the substation(s). 2 Despite the requirements of Regulation 14(2)(d) and Schedule 4(2) of the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017 the Environmental Statement does not consider the option of any offshore transmission systems despite there being evidence showing that SPR studied the alternative option of an offshore ring main. SPR has not complied with these regulations in failing to mention the reasonable alternatives that it has considered. SPR has relied on studies by National Grid in 2011. Since 2011 there have been significant advances in both technology and opportunities, given the increased demand for renewable energy and the associated infrastructure. 3 SPR’s failure to work with National Grid, Ofgem and the Government to properly explore offshore transmission systems is unreasonable given the significant harm that would be suffered as a result of the proposed on-shore development. There is therefore no compelling case in the public interest for making the DCO, nor in respect of compulsory purchase. 4 When planning applications for East Anglia ONE and East Anglia THREE were submitted, East Anglia ONE North and East Anglia TWO were at the pre-application stage. Considering East Anglia Three was consented as recently as 2017, why was consideration not given to future developments and their need for an onshore substation? SPR has also failed to provide evidence as to why Bramford has been disregarded. 5 Planning Inspectorate Advice Note Seventeen – Cumulative Effects Assessment – provides an overview of the cumulative effects assessment process that applicants should adopt for NSIPs. Given the already well-known and established 'other existing development and/or approved development' both locally and regionally, onshore and offshore, (including the Nautilius Interconnector) this approach has not been followed. 6 The cumulative impact assessment for traffic and transport only considered the impacts of the proposed East Anglia ONE North project and the proposed East Anglia TWO project. This is inadequate. The traffic and transport aspects of the Proposed Development should be much broader to the numerous existing and/or approved developments locally and regionally. The assessment should include the wider road network, including the Orwell Bridge which is the primary route to the Proposed Development's onshore substation and cable route, as well as being the primary route for many other developments in the region. 7 The Cumulative Impact Assessment traffic and transport associated with Sizewell C is qualitative and not quantitative – eg. it does not consider the increased number of HGV movements through the local road network. This is not acceptable due the significant potential environmental, economic and social impacts. 8 Cumulative impacts between East Anglia ONE North and East Anglia TWO were assessed as being not significant. This is incorrect, as whether East Anglia TWO is constructed simultaneously or sequentially, there will be increased traffic locally and regionally. It appears that the "not significant" finding is based on the landfall and cable route only and has not taken account of the substation construction. 9 The Environmental Statement fails to consider how construction traffic will get to the substation site. The onshore highways study area is incorrect as it does not include the B1121. 10 In previous correspondence at the stage 3 and stage 4 consultation stage I noted that: 10.1 The approach to site selection is flawed; 10.2 In assessing alternative sites, insufficient weight was given to the actual landscape and character of the potential sites; and 10.3 The substantial detrimental economic impact on the largely tourist dependent economy of this area of East Suffolk has not been properly taken into account, including the additional burden of increased unemployment and social care. 10.4 Landscape impacts have not been properly assessed, and insufficient weight has been placed on the impact on landscape and character. 11 SEAC’s legal team (Trowers & Hamlins LLP) has engaged in correspondence with the Secretary of State for Business, Energy and Industrial Strategy. Trowers & Hamlins LLP is seeking confirmation of whether further consideration is being given to the policy and strategy relating to the potential for an off-shore ring main. A compelling case in the public interest for the confirmation of the DCO cannot be established until a full and proper consideration of Government Policy in this area has been concluded.