Representation by Essex Suffolk Norfolk Pylons (Essex Suffolk Norfolk Pylons)
- Date submitted
- 14 November 2022
- Submitted by
- Members of the public/businesses
My representations will focus on cumulative impact and functional interdependence of projects. We believe that the inspector should consider why East Anglia GREEN (National Grid’s 180km power line proposal from Norwich to Tilbury) has not been considered under cumulative impacts in the Sheringham/Dudgeon Environmental Statements. Background: - In all (NG) Future Energy Scenarios, the East of England will be a power exporting region. - The EAG project website says, “A need was identified to resolve electrical boundary issues in East Anglia. There are three onshore power boundaries where additional system flexibility is required to ensure that power generated in the area from offshore windfarms and nuclear generation has more ways to flow into the wider transmission network during maintenance or faults on the system.” Our understanding is that Equinor’s Dudgeon/Sheringham schemes will require the additional capacity of EAG, and National Grid will be able to confirm this. FUNCTIONAL INTERDEPENDENCE If it is therefore the case that the Equinor projects cannot practically proceed without East Anglia GREEN, this falls under the ‘functional interdependence’ element of case law (Burridge v Breckland DC 2013 and Wingfield, R v Canterbury City Council 2019 ) Functional interdependence is where one part of a development could not function without another. This may indicate that they constitute a single project for cumulative impact purposes. In addition, a Scoping Opinion by the Planning Inspectorate for a Proposed North Wales Connection found that, “The ES should give equal prominence to any development which is related with the proposed development to ensure that all the impacts of the proposal are assessed.” It also said that, “In assessing cumulative impacts, other major development should be identified through consultation with the local planning authorities and other relevant authorities on the basis of those that are [amongst others]: • Projects on the National Infrastructure’s programme of projects.” East Anglia GREEN is a Nationally Significant Infrastructure Project. Without EAG (or an equivalent coordinated offshore grid that is the alternative lobbied for by Essex Suffolk Norfolk Pylons action group www.pylonseastangliac.o.uk) the East Anglian grid will not have the capacity for the power from the Equinor projects submitted in this DCO. The two are functionally interdependent.