Representation by Rt Hon Dr Therese Coffey MP
- Date submitted
- 27 January 2020
- Submitted by
- Members of the public/businesses
The Planning Inspectorate National Infrastructure Planning 27 January 2020 RE: DCO APPLICATION – EAST ANGLIA ONE NORTH & EAST ANGLIA TWO (EA1N & EA2) I write in relation to the two Development Consent Order applications above. It is my intention to submit this same response to both applications as the onshore infrastructure required to facilitate them is for both windfarms, not just one - notably the cabling running westward from Thorpeness to connect to the new substations proposed at Friston. It is for that reason that I argued that they should be determined as one application but the decision to accept them as two separate applications has already been made. At the outset, I wish to reinforce my support for the principle of offshore wind generation. I was Environment Minister when the Government first made the commitment to get to net zero carbon emissions by 2050. The UK already has much offshore wind capacity and more is planned right around the country. Facilitating offshore wind farms is an important aspect of that pledge. I have no specific objection to the offshore elements of these two applications per se though they will need to meet the appropriate environmental assessment. As Environment Minister, I secured the recognition of the natural marine and onshore environment by government for consideration on infrastructure projects. The issue though in this application (in both these applications) is how best to connect these strategic offshore energy sites to the national grid. Throughout the consultation stages, I have suggested alternatives to Scottish Power Renewables, including the proposed nuclear site at Bradwell, which would have meant less onshore cabling and substations in a more appropriate location. SPR have chosen not to pursue that, which in my view would have made their applications acceptable and are instead proposing a 32-metre wide cabling corridor across 9km of sensitive landscape with large substations on the edge of Friston village, without adequate landscaping. My biggest concern is the size and scale of the substations proposed at Friston, which will have a devastating impact on the local environment including on local listed buildings which surround the substation site. Paragraph 151 of the National Planning Policy Framework (NPPF) states that ‘plans for renewable energy should ensure that adverse impacts are addressed satisfactorily, including cumulative landscape and visual impacts.’ SPR’s submission doesn’t do that, especially when you consider all the other energy infrastructure which has been planned for this part of the Suffolk coast. This was the point made by the large number of people who attended my public meeting, which goes to show the strength of feeling locally. There is also a danger that the substation will need to be even bigger than planned. While I understand it is the intention to use SF6 cooling rather than air cooling to significantly reduce the size of the power stations, this cannot be taken for granted given the government’s ratification of various amendments to the Montreal Protocol and the Kyoto Protocol, which aims to reduce significantly the use of fluorinated gases as, if released, they are very potent greenhouse gases. Air cooling infrastructure is much much larger and would be a far worse outcome. When SPR first proposed Friston as a site for substations, I was clear that at the very minimum – on the basis of planning conditions if the inspectorate was minded to recommend the DCO be granted - they should dig them into the ground to reduce the visual impact. This does not form part of their plans and their proposed planting to screen the development is woefully inadequate, especially when you take into consideration the growth rates of their landscaping mitigation. This really needs further evaluation. The proposed cabling does not comply with paragraph 151 of the NPPF either as instead of facilitating a connection to the grid as close to shore as possible, the proposal for 9km of underground cabling will cause a significant impact on the landscape including elements of the AONB and the removal of a section of protected woodland close to Aldringham Court, a grade II listed building. I understand that the width of the cable route will be reduced to 16.1m at sensitive locations but despite that, will also cause the loss of a number of hedgerows, interspersed by significant trees. This is in direct opposition to paragraph 170 of the NPPF, which calls for the protection and enhancement of valued landscapes. I am also really concerned about the proximity of the cabling corridor to residential properties and have received correspondence from concerned constituents about the impact it will have locally. There are no details about how these works will be managed. There are also concerns about how the cabling comes onshore at Thorpeness and the impact of drilling on the stabilisation of the cliffs. I also have significant concerns about the economic aspect of these proposals and the impact it will have on our precious tourism industry. The disruption the onshore infrastructure will cause during the development phase and the lasting impact on the beauty of this part of Suffolk will have an impact on visitor numbers and the livelihoods of local residents. The cumulative impact of other energy infrastructure projects also needs to be taken into account. I am aware of the submissions made by other groups, including the parish council, district council and county council. I support their arguments. In conclusion, the impact of this proposal on the countryside, vital habitats, heritage assets, the amenities of local residents and tourism means I that I formally object these DCO applications and I urge the Planning Inspectorate not to recommend them to the Secretary of State rather that they are refused. Yours sincerely, Rt Hon Dr Therese Coffey MP