Representation by North Norfolk District Council (North Norfolk District Council)
- Date submitted
- 14 November 2022
- Submitted by
- Local authorities
Sheringham and Dudgeon Extension Projects Application Ref: EN010109 Submission of Relevant Representation North Norfolk District Council (NNDC) has been notified by Equinor New Energy Limited on 05 Oct 2022 that their application for Development Consent Order (DCO) in respect of Sheringham Shoal Extension Project and Dudgeon Extension Project (SEP & DEP) has been accepted for examination by the Planning Inspectorate under the Planning Act 2008. This letter forms the Relevant Representation of NNDC and sets out a summary of the issues that are considered to be relevant to the nationally significant infrastructure project as it passes through the North Norfolk district. Principle of Development North Norfolk District Council is fully supportive of the principle of renewable energy development in helping to tackle the challenges faced by climate change. NNDC recognises the national importance of having a balanced supply of electrical generation including increasing renewable energy supplies from offshore turbines in helping decarbonise the UK’s energy sector. Whilst recognising the national importance of offshore wind, North Norfolk District Council believes it is essential to ensure that key design and construction decisions do not result in unacceptable or adverse impacts on residents or businesses within North Norfolk, acknowledging the important contribution that agriculture and tourism plays in the economic prosperity of the District underpinned by the nationally and internationally recognised coast, landscape and biodiversity interests as well as significant heritage assets that help define the unique character of the area. Keys Aspects of the Project Affecting North Norfolk North Norfolk District Council’s jurisdiction extends inland from the Mean Low-Water mark along the coastline. The key design/construction decisions affecting North Norfolk include: • Method of bringing offshore cables onshore at Weybourne; • Working Corridor of onshore cable route; • Use of Horizontal Directional Drilling onshore; • Impact of construction traffic; • Landscape & Biodiversity Mitigation; • Phasing of the Project and Associated Construction Timetable(s); • Community Benefits Method of bringing offshore cables onshore at Weybourne NNDC welcomes the bringing of the offshore cables onshore via the use of the horizontal directional drill (HDD) method which will help reduce the potential significant adverse impacts from open trench construction in the Weybourne area. It is important that this method is secured as part of any DCO. Working Corridor of onshore cable route NNDC noted the onshore construction parameters at PEIR stage. NNDC will work with Equinor New Energy Limited to ensure that all appropriate measures are secured within the DCO to minimise the impact of the onshore cable route including through the use of ducted systems to help reduce construction disturbance. Experience from other Offshore wind DCO applications indicates that both parties, working together positively, can secure the necessary measures to reduce adverse impacts during the construction phases through a Code of Construction Practice and agreeing Construction Hours. Use of Horizontal Directional Drilling (HDD) onshore NNDC welcomes the use of Horizontal Directional Drilling (HDD) techniques so as to avoid sensitive or designated sites so as to minimise any potential impacts upon them. NNDC will work with Equinor New Energy Limited to ensure that all appropriate measures are secured within the DCO to minimise the impact of the onshore cable route through use of HDD onshore at appropriate locations. Impact of construction traffic Within North Norfolk it is assumed that the main traffic generators connected with Sheringham Shoal Extension Project and Dudgeon Extension Project will come from construction traffic associated with: • Bringing the offshore cables onshore at Weybourne; and • Construction of the cable corridor. North Norfolk has many small and narrow country roads with restricted widths and limited opportunities for larger vehicles to pass each other. Traffic levels vary but tourism during March to October (heighted during the summer months especially near coastal locations) means that the timing of any construction works will be critical to minimising adverse highway impacts. NNDC, through Norfolk County Council as Highway Authority, will work with Equinor New Energy Limited to ensure that all appropriate measures are secured within the DCO to minimise the traffic impact of the proposals. Landscape & Biodiversity Mitigation NNDC recognises that it will be important during the examination to ensure any likely adverse impacts relating to landscape and biodiversity interests are properly captured and appropriately managed and mitigated through the DCO requirements. Consideration will also need to be given to the timing of enhancement/mitigation works, particularly in view of the potential for the project to be split in to two phases. NNDC will work with Equinor New Energy Limited to ensure that all appropriate measures are secured within the DCO to minimise landscape and biodiversity impacts. Phasing of the Project and Associated Construction Timetable(s) Clarity over Construction timetabling is a matter that NNDC would seek to be considered further, as part of the examination process, in order that any adverse impacts of construction in a single or two phase programme can be properly understood and appropriately managed for the benefit of residents and businesses within the District. Works are shortly about to commence for the Ørsted Hornsea Project 3 which has similar landfall location and similar grid connection location. It will be important to ensure that the SEP & DEP projects do not detrimentally affect any mitigation measures secured as part of the Hornsea 3 project. NNDC will work with Equinor New Energy Limited to ensure that all appropriate measures are secured within the DCO to minimise conflicts. Community Benefits In respect of potential community benefits, NNDC recognises that the DCO process has to work within the sphere of planning law and under the notion that planning obligations should only be sought where they are necessary to make the development acceptable in planning terms; directly related to the development; and fairly and reasonable related in scale and kind to the development. NNDC recognises that, once built, the scheme is likely to be relatively benign. However, the authority believes that it is important that the proposals sufficiently address any harmful impacts associated with construction including potential damage to coastal areas, loss of trees and hedgerows along and associated with the cable corridor, damage to roads and verges from traffic together with consideration of harm to the economic prosperity of businesses affected by any extended or multi-phased construction activities. The Council believes it will therefore be important for the examination panel to carefully consider and understand the package of CIL compliant benefits being put forward by Equinor New Energy Limited as part of the consent process and how those benefits would be secured. Outside of the DCO process, North Norfolk District Council will seek to negotiate with Equinor New Energy Limited to secure a range of benefits for the wider community of North Norfolk. Summary Whilst NNDC is supportive of the principle of the Sheringham Shoal Extension Project and Dudgeon Extension Project offshore wind developments being proposed by Equinor New Energy Limited, the Council believes it will be important to ensure the project(s) are managed and delivered in a way that does not result in significant adverse impacts on local communities and businesses close to the landfall and along the onshore cable route. North Norfolk District Council look forward to being engaged in the examination / DCO process moving forward, albeit, given the relatively modest scale of the project, it is anticipated that most , if not all of the issues, can be resolved through the Statement of Common Ground and written exchanges such that attendance at the Examination should be able to be limited. Yours sincerely Geoff Lyon Development Manager