Representation by The Ogilvie Family Trust (The Ogilvie Family Trust)
- Date submitted
- 27 January 2020
- Submitted by
- Members of the public/businesses
ALTERNATIVE LANDFALL OPTIONS We are aware that the Government are considering an alternative strategy proposed 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 being available and therefore the potential removal of the need to develop both the cable route and transformer site as currently proposed. CONSULTATION AND ENGAGEMENT While there have been constructive and proactive face to face meetings with SPR and it’s agents, the detail required by the landowners or occupiers has either been provided late or has not been available. For example, details on timings of construction to be able to understand the impact on the cropping rotation of the farm, the detailed cable route and the locations for the temporary working areas (Construction Consolidation Sites). This lack of information has made it difficult for the landowners/ occupiers to plan their businesses going forward, particularly if they intend to invest in new infrastructure or buildings which in general will not be permitted in the areas required for the Project. We ask that, going forward, information required by the landowners is provided promptly when requested. TIMING OF CONSTRUCTION WORK To date, Scottish Power Renewables (SPR) have been unable to advise in any detail on the likely timing for the construction of the Project East Anglia ONE North (EA1N), nor how its development will be tied into the Project SPR are developing in parallel, East Anglia TWO (EA2), the subject of a second Development Consent Order (DCO). The landowner(s) and / or occupier(s) are concerned about the cumulative impact of the two Projects and believe that it is essential that both Projects are built simultaneously to mitigate the effect on their property and the resulting losses incurred, with the total build period not to exceed two years from the date of entry. NOTICE OF ENTRY Should the DCO be approved, landowners and occupiers would require a minimum 12 month period of Notice (ideally 18 months) prior to entry being taken to their land. 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 should be engaged by SPR to carry out a pre and post construction assessment of the impact that the proposed construction of the onshore infrastructure associated with the Project (EA1N) will have or has had on drainage and, prior to undertaking the proposed drainage schemes, will consult with the landowner and occupier 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. We note from the Outline Code of Construction Practice (OCoCP), reference to the preparation of a Soil Management Plan and that the appointed contractor will be required to comply with this. We have not had the opportunity to review or comment on this plan, 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 and condition 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; • an Agricultural Liaison Officer to be appointed to oversee the implementation of the Soil Management plan and to act as a liaison between the landowners(s), occupier(s) and contractors. IRRIGATION It is noted that the OCoCP does not address the issue of management and maintenance of individual landowners and occupiers field irrigation systems. We consider that the following requirements should be included as a minimum; • prior to the commencement of any 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 land previously 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. DUST Clarification is required on how practical issues, like dust, will be controlled during the construction period. ACCESS If the DCO is confirmed, defined routes of access for pre-construction works, the construction works and post construction 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. RESTRICTIONS It is accepted that over the easement width, it would be inappropriate to construct permanent buildings or facilities that would impinge on SPR’s ability to access the cables. However, such restrictions should not extend to semi-permanent works, such as the construction of areas of hardstanding (for storage or parking purposes) and / or tracks undertaken using hardcore and other loose fill material. It is essential that the areas of land subject to any permanent restrictions as a result of the Project are kept to a minimum. DEPTH OF CABLES We note from the OCoCP, that the onshore cables will typically be laid in trenches approximately 1200mm below ground level. To date, landowners and occupiers have been advised that there will be a restriction on the depth to which cultivations can be undertaken without prior approval from SPR of 650mm which is insufficient. Taking account of the prevailing soil type, i.e. light sandy soil, the geographical location of the cable route (close to the East Coast) then it is considered that there is a high propensity for ‘wind blow’ to be a significant factor over the anticipated life of the Project. To this end, the proposed typical depth of 1200mm is considered insufficient and that as a minimum, the cables should be laid at a depth of 1500mm. Increasing the depth of the cables, will also enable the restriction on cultivation depth (without prior approval) to be increased to 950mm. WORKING HOURS The proposed working hours within the OCoCP, 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 DCO to enable enforcement. There should be no exceptions other than in response to emergency situations. CONSTRUCTION MITIGATION MEASURES We note from the OCoCP, that noise and vibration management measures are to be implemented during the construction period and brief details of these have been 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. 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.