Representation by Mr J H Rogers (Mr J H Rogers)
- Date submitted
- 27 January 2020
- Submitted by
- Members of the public/businesses
TIMING OF CONSTRUCTION WORK To date, SPR have been unable to advise in any detail on the likely timing for the construction of the Project, EA1 North, nor how its development will be tied into the other associated Project, EA2, the subject of a second Development Consent Order. Mr Rogers is concerned about the cumulative impact of the two Projects, if built separately, and believes that it is essential that both are built simultaneously to mitigate the effect on his property and the resulting disturbance caused. NOTICE OF ENTRY Should the Development Consent Order be approved, Mr Rogers considers that property owners and occupiers will require a minimum 12 month period of Notice (ideally 18 months) prior to entry being taken to their land to minimise crop loss and disturbance arising therefrom. ABOVE AND BELOW GROUND STRUCTURES Jointing Bays should all be located underground, so as not to interfere with normal agricultural operations. Should Link Boxes be required, then these should be located within a tight cluster set level to the surrounding ground level (save as where otherwise agreed) within or adjacent to field boundaries. Our preference is that all Link Boxes are located within field boundaries. No clarification has been received from SPR as to how many, if any, Link Boxes will be required. FIELD DRAINAGE Drainage consultants with relevant practical experience and experience of working in Suffolk will need to be engaged by SPR to carry out a pre and post construction assessments of the impact that the proposed construction of the onshore infrastructure associated with the Project, EA1 North, will have or has had on drainage and, prior to undertaking any proposed drainage schemes, will consult with landowners and occupiers and their appointed drainage consultant on the design of any land drainage works required in connection with the construction works and on the design of any land drainage works required for the subsequent restoration of drainage on the landowners’ / occupiers retained land. SOIL MANANGEMENT The treatment and reinstatement of soil during and after construction is one of the main issues of concern. Limited information has been provided, to date, to landowners and occupiers. It is noted from the Outline Code of Construction Practice, reference to the preparation of a Soil Management Plan and that the appointed contractor will be required to comply with this. Mr Rogers has not had the opportunity to review or comment upon this, but the following requirements should be included, as a minimum; • prior to the commencement of work, detailed testing should be undertaken to establish existing soil nutrient values and soil profiles over both the working areas and adjacent land which will be sterilised from production; • details of soils handling, storage, management and reinstatement; • details of post completion soils testing and aftercare management. IRRIGATION It is noted that the Outline Code of Construction Practice does not address the issue of management and maintenance of individual landowners and occupiers field irrigation systems. Mr Rogers considers that the following requirements should be included as a minimum; • prior to the commencement of work, all field irrigation systems in the vicinity of the works should be identified and recorded. • following consultation with individual landowners and occupiers, independent irrigation consultants / contractors should be appointed to advise on both temporary and, where necessary, permanent diversions of irrigation mains to ensure that throughout the construction period SPR maintain water supplies to any areas severed by the works, to ensure that all previously land capable of irrigation remains so. FLOOD ISSUES No details have been provided to landowners and occupiers on how any increase in surface water run off from the haul road and the temporary working areas will be managed and dissipated during the construction period. Clarification of this should be provided by SPR as part and parcel of the planning process. DUST Clarification is required on how practical issues, like dust arising from the works, will be controlled during the construction period. ACCESS If the Development Consent Order is confirmed, defined routes of access for pre-construction works, the construction work and post commencement remedial works and maintenance will need to be agreed with individual landowners and occupiers. It is noted that no detail has, to date, been provided to landowners and occupiers as to how they will access land severed by the construction works, which will need to be agreed prior to the commencement of the work. WORKING HOURS The proposed working hours within the Outline Code of Construction Practice of 7.00am to 7.00pm, Monday to Friday and 7.00am to 1.00pm on Saturday’s, with no construction works on Sundays or Bank Holidays, are acceptable and should be confirmed in the Development Consent Order to enable enforcement. CONSTRUCTION MITIGATION MEASURES We note from the Outline Code of Construction Practice, that noise and vibration management measures are to be implemented during the construction period and brief details of these are provided. We would ask that as a minimum, more detailed consideration of physical mitigation measures that could be undertaken during the construction period to minimise disturbance to local residents are considered, including strategic banking of topsoil to form an acoustic bund. In particular Mr Rogers considers that at the outset of the development, stripped topsoil from the development site should be used to form an acoustic bund between his property and the development site to enable the subsequent planting of semi-mature trees, shrubs and hedging in the first planting season thereafter to mitigate the noise emulating from the development site (please see ‘Landscaping’ below). DEVELOPMENT MITIGATION – LANDSCAPING The documentation in support of the Development Consent Order indicates that a belt of trees are proposed to be planted between Friston Moor Farm Barn and the development site for the transformers and sub-stations. Whilst this is welcomed, despite repeated requests to alter the ‘angle’ and ‘extent' (length) of the landscaping belt, SPR have to date been unable to provide further assurance that such constructive comments will form part of the final consideration for the development to ensure that the development is adequately screened in the long term from the property. It is requested that before the Development Consent Order is confirmed, property owners in the immediate vicinity of the development be given the chance to directly comment to the Planning Inspector on the suitability of proposed landscaping proposals. CREATION OF NEW PUBLIC RIGHTS OF WAY The documentation in support of the Development Consent Order proposes the creation of additional public rights of way over the land to be acquired by SPR for the development of the new transformer and sub-station site. It is requested that the location / positioning of the proposed new rights of way are discussed in detail with the adjoining property owners so as to mitigate their privacy and security, which is now at threat. ALTERNATIVE LANDFALL OPTIONS We are aware that the Government are considering an alternative strategy for delivery of the energy produced by offshore windfarms to the National Grid, with an emphasis to rationalise the number of individual connections and cable route requirements through the construction of an offshore ring main. The question arising from this given the potential timescale for the development of this Project, is whether due consideration has been given to the likelihood of this option and therefore the potential removal of the need to development both the cable route and transformer site as currently proposed. REQUEST TO ATTEND HEARINGS AND REPRESENTATIONS The landowner and / or agent requests to make oral representations at the Compulsory Acquisition Hearing or any other Hearings that may be held.