Representation by Vattenfall Wind Power Limited (Vattenfall Wind Power Limited)
- Date submitted
- 11 November 2022
- Submitted by
- Members of the public/businesses
Norfolk Boreas Limited (Norfolk Boreas) has received notification that the Sheringham Shoal Extension Project (SEP) and the Dudgeon Extension Project (DEP) have been accepted for examination. Please accept this letter as Norfolk Boreas’ representation that it has an interest in the SEP and DEP applications, and wishes to be treated as an interested party for the purposes of the examination process. Development consent was secured for Norfolk Boreas on 10th December 2021. In principle, Norfolk Boreas supports the SEP/DEP as it will provide an important contribution towards meeting the government's renewable energy targets, and will enable the UK to continue its growth in the offshore wind sector. If consented, there is the potential for interaction between the projects and Norfolk Boreas is keen to ensure, where appropriate and to the extent necessary, that this is considered during the SEP/DEP examination. Norfolk Boreas has undertaken a preliminary review of the documents provided in support of the SEP/DEP application and its initial comments, focusing primarily on the cumulative effects as assessed in the Environmental Statement (ES) and the in-combination assessment contained in the Report to Inform Appropriate Assessment, are set out below. In general, Norfolk Boreas welcomes the findings of the cumulative and in-combination assessments between Norfolk Boreas and the SEP/DEP where Norfolk Boreas has been included. However, it is noted that for a number of pertinent topics where Norfolk Boreas has been referenced by name within the relevant chapter, detailed assessment has not been included. Given the similarity of the nature of the SEP/DEP and Norfolk Boreas, Norfolk Boreas is keen to continue to work collaboratively with Equinor New Energy Limited, particularly in relation to the following topics in which cumulative effects with Norfolk Boreas have not been assessed in detail: • Marine mammals • Offshore ornithology • Commercial fisheries • Traffic and Transport • Socio-economics • Aviation and radar • Noise and Vibration • LVIA • Historic Environment Some further detail is provided on key topics of interest below (but not necessarily limited to these topic areas). Cable Crossing Location The DEP/SEP proposed cable corridor crosses the Norfolk Boreas cable route in the Parish of Oulton. Vattenfall Wind Power Ltd would expect that any rights granted will not acquire, extinguish, suspend, override or interfere with any rights that Vattenfall Wind Power Ltd has in respect of any apparatus already installed or permitted to be installed at this location. Vattenfall Wind Power Ltd also expect to maintain unfettered access during their construction phase and beyond for inspection and repair. Vattenfall Wind Power Ltd will seek to ensure that there are suitable protections in place for the easement area and infrastructure included, or proposed to be included within it. The Street, Oulton Whilst the siting of the offshore array, export cable route and the onshore connection points differ between Norfolk Boreas and the SEP/DEP, Vattenfall Wind Power Ltd notes that the proposed DEP/SEP onshore cable will still cross The Street, near Oulton airfield. Whilst the DEP/SEP construction traffic numbers presented at Preliminary Environmental Information Report (PEIR) on The Street are very low, Vattenfall Wind Power Ltd would expect Equinor New Energy Limited to demonstrate that their approach to that crossing, and use of The Street to access works either side of The Street, would not conflict with mitigation measures already secured for Norfolk Boreas. Specifically the introduction of passing places along The Street and a cap on the maximum number of Heavy Goods Vehicles permitted to use that route. The A1067 The A1067 (the main route serving the preferred DEP/SEP main construction compound location) is also a road link for construction traffic for Norfolk Boreas. Vattenfall Wind Power Ltd would expect the reported Norfolk Boreas construction traffic numbers to be factored into Equinor New Energy Limited’s assessment of cumulative traffic impacts on the A1067 as part of their application. B1149 Access The DEP/SEP boundary overlaps with two construction accesses required by Norfolk Boreas; one is required to undertake a trenchless crossing of the B1149 for Norfolk Boreas and the other is near the junction of The Street and Heydon Road which is required to access the Norfolk Boreas cable logistics area. Both accesses are also required for cable pulling operations for Norfolk Boreas post duct installation. Vattenfall Wind Power Ltd therefore require assurances that the proposed routing of the DEP/SEP cables would not impact the construction programmes for Norfolk Boreas; both at these construction accesses and across the onshore cable route. Marine Mammals Vattenfall Wind Power Ltd note that both the DEP/SEP projects include monopile and piled jacket options for foundations and that although only indicative programs for construction have been provided at this stage there is potential for the Unexploded Ordnance (UXO) clearance and piling activities to overlap with the construction programme for Norfolk Boreas (possible piling overlap). Equinor New Energy Limited have identified the potential for cumulative impacts for a number of species including harbour porpoise, bottlenose dolphin, white beaked dolphin, minke whale, and grey and harbour seal. Given the potential for overlapping construction programmes it will be essential that Equinor New Energy Limited keep Vattenfall Wind Power Ltd and Norfolk Boreas updated as UXO and construction programmes are developed and once more certainty around these timeframes is available. The Norfolk Projects note that the DEP/SEP projects are located outside of the Southern North Sea Special Area of Conservation (SAC) but are within 14.1 km at the closest point. Therefore, there is potential for Likely Significant Effects on the SAC to occur. It will therefore be important to consider the cumulative effects of the DEP/SEP projects with the Norfolk projects within the Habitats Regulations Assessment (HRA) and further information on timing of activities will be key to reducing the risk of possible effects to the SAC. Offshore Ornithology Collision risk predictions were presented in the DEP/SEP PEIR and, as advised by Natural England, these were included in a revised cumulative assessment for Norfolk Boreas. The updated predictions presented in the DEP/SEP application do not significantly differ from those presented at PEIR. The DEP/SEP HRA and integrity matrices identify an in combination effect on the kittiwake feature at the Flamborough and Filey coast Special Protection Area (SPA) and therefore propose compensation for this feature. The Norfolk Projects (the combination of Norfolk Boreas and Norfolk Vanguard Limited) note that DEP/SEP are proposing the upgrading or increase in capacity of existing kittiwake colonies which have established on artificial structures. One option is the creation of narrow ledges on one wall of the BT building in Lowestoft. The Norfolk projects are intending on installing Kittiwake nesting structures on the outer port at Lowestoft in the near future and therefore there would be potential for the two compensation measures to interact. Although, the number of nests which Equinor New Energy Limited are proposing to provide for is much smaller than the Norfolk projects it will be essential for Equinor New Energy Limited to keep the Norfolk Projects updated on its progress as the Norfolk Projects are further developed than DEP/SEP in terms of its delivery programme. In particular, and to the extent available, Norfolk Boreas would welcome sight of further detail from the SEP and the DEP on the relevant topics. Norfolk Boreas hopes that this additional data can be shared as part of the continued dialogue between the projects.