Representation by National Trust (National Trust)
- Date submitted
- 14 November 2022
- Submitted by
- Members of the public/businesses
The National Trust wishes to register as an interested party in respect of the application for a Development Consent Order for the Sheringham and Dudgeon Extension Projects. The National Trust (“the Trust”) owns Sheringham Park, located to the east of Weybourne on the North Norfolk Coast. The estate includes 1000 acres of varying habitat including woodland, parkland and cliff top, and the Grade II* Sheringham Hall. The Trust operates a major visitor-based business at Sheringham, supporting and promoting its preservation work. In 1997, pursuant to section 21 of the National Trust Act 1907, Weybourne Woods were declared “inalienable”. This status enables the Trust to live up to its core charitable objective of preserving places of historic interest and natural beauty for the nation, forever. The proposed Onshore Works Plans include a cable corridor (and access route) for onshore connection works which would pass through Trust owned land at Weybourne Wood which is part of the Sheringham Estate and part of the designated Norfolk Coast AONB. Equinor proposes to compulsorily acquire new permanent and temporary rights over the Trust’s inalienable land at Weybourne wood, at a width of 100m for trenchless crossings. The Trust does not object to the principle of the proposed Sheringham and Dudgeon Windfarm Extension Projects. However, we do not support proposals that would seriously damage the integrity of any archaeological remains on the Estate, have an adverse impact on views from Sheringham Park or its biodiversity, or give rise to an adverse effect on the integrity of the Sandwich tern feature of the North Norfolk Coast SPA without a satisfactory derogation case. As it currently stands, the Trust has these three outstanding concerns, and therefore objects to the proposed DCO due to: • The impact of the current proposals on the little understood archaeology of the Estate; • The impact of the current proposals on Sandwich terns (an SPA feature) on the North Norfolk Coast; and • Landscape, visual and ecological impacts on the Sheringham Estate. Archaeology The Trust has a duty to protect our heritage and all archaeology within its care. The proposed groundworks pass through a wooded area of the wider Sheringham Estate, within the historic parkland. Whilst the exact area of the proposed groundworks has not had a formal archaeological survey, the adjacent woodlands have been thoroughly surveyed, revealing networks of medieval and post-medieval wood banks, quarry pits of medieval to modern date and a number of WWI and WWII defensive features. Furthermore, there exists an extant scheduled prehistoric barrow to the southeast of the proposed groundworks indicating that the wider area is likely home additional prehistoric settlement and/or funerary activity. It is imperative then, that the woodland is subject to archaeological and historic landscape surveys prior to any groundworks, inclusive of vehicle movement. Areas proposed for development and the wider environs should be subjected to full and extensive UXO survey. No formal agreement has been reached with Equinor as to how the Trust, County Council Archaeologist and developer might work together to achieve a suitable and appropriate methodology for the archaeological work to be undertaken on the Estate prior to any development. Impact on Sandwich terns The Trust manages an important colony of Sandwich terns on the Norfolk coast at Blakeney Point, alongside Natural England at Scolt Head Island National Nature Reserve. The tern colony alternates between the two sites and represents approximately a third of the UK Sandwich tern population. This colony will be adversely impacted by the proposed development, as recognised in the supporting documentation predicting a loss of up to 28 birds per annum through collision or displacement. Compensation measures are proposed at Loch Ryan, Scotland (nesting habitat enhancement to recover population) and in the Farne Islands (improved breeding success). However, the Trust is not confident that these will be effective at the Farne Islands or demonstrate additionality and no agreement has been reached with the developer about compensation measures on our land. Landscape, Visual & Ecological Impacts Weybourne Woods was declared inalienable in order to protect views from Sheringham Park and prevent inappropriate development. Construction impacts on Weybourne Woods and the AONB have been identified as major-moderate significance and adverse. Furthermore, it is proposed to remove an area of forestry. It is not clear to the Trust what landscape, arboricultural and ecological mitigation and enhancements are proposed. Acquisition of Land and Rights over land The Trust notes that the Book of Reference refers to the compulsory acquisition of rights over Trust land and that part of the cable corridor will cross Trust inalienable land. The Trust has been working with Equinor to agree terms of this access that will cause minimal impact and disruption and with a view to securing a signed Option Agreement and Deed of Easement for the requisite cables and access over and under Trust land. However, at the time of writing, terms have not yet been agreed. Therefore, the Trust’s concerns about this application as expressed here remain unaddressed. These matters will be expanded upon in our Written Representation in due course.