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Representation by National Grid Electricity Transmission Plc (National Grid Electricity Transmission Plc)

Date submitted
17 March 2022
Submitted by
Other statutory consultees

Representation by National Grid Electricity Transmission Plc to the Sunnica Energy Farm Project (“the Project”) Introduction National Grid Electricity Transmission Plc (NGET) wishes to make a relevant representation to the Project in order to protect their position in relation to infrastructure and land which is within or in close proximity to the proposed Order limits. NGET’s rights to retain its apparatus in situ and rights of access to inspect, maintain, renew and repair such apparatus located within or in close proximity to the Order limits should be maintained at all times and access to inspect and maintain such apparatus must not be restricted. NGET Land and Infrastructure Impacted The documentation and plans submitted for the Project have been reviewed in relation to impacts on NGET’s existing apparatus and land interests located within this area. The following assets, which form an essential part of the electricity transmission networks in England and Wales are within, or in close proximity to, the Order limits: Substations • Burwell Main 400kV Substation • Burwell Main 132kV Substation Overhead Lines • 4ZM (400kV) overhead line Burwell Main – Walpole 1 • 4ZM (400kV) overhead line Burwell Main – Walpole 2 Connection into Substation As part of the Project, the Promoter is proposing to connect to the National Grid Burwell Main 400kV substation and we understand that this would be done via a new 132kV substation to be constructed by the Promoter. NGET have the following initial comments: • As has been communicated to the Promoter, the Option 1 connection is not technically feasible given the amount of land now required by the Promoter, the planned extension of the substation and NGET’s license obligations. • Option 2 will therefore need to be taken forward. NGET would ask that Option 1 is removed from the dDCO; • The Grid Connection Statement refers to the Promoter’s own substation as the ’Burwell National Grid Substation Extension’. This will need to be renamed as it will not be a National Grid asset; • The Grid Connection Statement further sets out that “the Applicant has, or will have, the ability to procure the necessary land and rights in order to upgrade the Burwell National Grid Substation to accommodate the Grid Connection”. The Promoter will need to install user equipment inside the NGET substation but will not require any land rights to do so as this will be covered by the Interface Agreement between the parties; and • The dDCO currently contains that NGET have the benefit of Work 5C. NGET do not consider that this is necessary as these works will be undertaken by the Promoter. Compulsory Acquisition Powers NGET notes that the Book of Reference and Land Plans indicate that powers for the compulsory acquisition of rights and extinguishment of rights are included over NGET’s operational land including the National Grid Burwell Main Substation. Powers to compulsory acquire the freehold of land for the Option 1 connection now need to be removed as this is not technically feasible and, as set out above, the Promoter does not require land rights over the National Grid Burwell Main Substation as this will be covered by the Interface Agreement. NGET strongly opposes any compulsory acquisition or extinguishment of rights over its land. Any such powers would cause serious detriment to NGET’s ability to comply with its statutory duties. Protective Provisions NGET will require protective provisions to be included within the DCO to ensure that its interests are adequately protected and to ensure compliance with relevant safety standards. NGET is liaising with the Promoter in relation to the protective provisions for inclusion within the DCO along with any supplementary agreements which may be required. NGET will keep the Examining Authority updated in relation to these discussions. Summary As a responsible statutory undertaker, NGET’s primary concern is to meet its statutory obligations and ensure that any development does not impact in any adverse way upon those statutory obligations. NGET reserves the right to make further representations as part of the examination process but in the meantime will negotiate with the Promoter with a view to reaching a satisfactory agreement.