Representation by National Farmers Union (NFU) (National Farmers Union (NFU))
- Date submitted
- 14 November 2022
- Submitted by
- Members of the public/businesses
IN THE MATTER OF AN APPLICATION FOR A DEVELOPMENT CONSENT ORDER AND IN THE MATTER OF THE SHERINGHAM AND DUDGEON EXTENSION OFFSHORE WIND FARM PROJECTS AND IN THE MATTER OF THE NATIONAL FARMERS UNION AND THE VATTENFALL AGENTS KNOWN AS THE LAND INTEREST GROUP ______________________________ OUTLINE REPRESENTATIONS ______________________________ 1 Introduction 1.1 These are the Outline Representations of the National Farmers Union (“NFU”) to the application for a Development Consent Order by the Secretary of State for Business, Energy and Industrial Strategy identified as the Sheringham and Dudgeon Extension Offshore Wind Farm Projects order. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Outline Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar Offshore Wind Farm schemes. 2. Consultation and Engagement 2.1 There have been constructive and proactive face to face meetings with Equinor and their agents. Heads of terms were sent out and some of these have been signed by landowners who are in agreement to the main principles of the scheme but they have still been signed subject to caveats due to outstanding queries which have not been answered by Equinor or where agreement has still not been reached. There has been no contact from Equinor in the last few months with no more detail forthcoming. The NFU and agents acting for clients and members are yet to see a voluntary option agreement. 3.0 Term 3.1 A term is being sought in perpetuity and agreement has not been reached with Equinor on this as on all other offshore wind farm schemes a term of 99 years has been agreed. The NFU has been given no reason as to why the Sheringham and Dudgeon schemes need to be in perpetuity. 4.0 Cables and Ducting 4.1 There is still ongoing concern with Equinor over the scheme being two projects under one DCO. The NFU has made it clear that it is looking for Equinor to lay the first set of cables in ducts so that the second set of cables can be pulled through the ducting. This will cause less interference to landowners and occupiers by reducing the impact on operations on the land. The NFU really does not want the projects to go ahead sequentially as the easement width required is greater and the timing and construction of works is too long. 4.2 The NFU would like to see cables with a minimum depth of 1.2m to the top of the tile. It does understand that there may be engineering reasons for the cable/ducting to deeper or shallower. Where this occurs landowners and occupiers must be provided with a plan to highlight where the cable is shallower. 5. Construction and Funding 5.1 Landowners from the start were notified by Equinor that the project is two schemes Sheringham and Dudgeon even though only one DCO. It is understood that Equinor may not be willing to lay cables in ducts for one project for the cables of the second project, as each project will only fund its own cables. Due to issues highlighted above over easement width and construction times this must be addressed at the examination. Questions still need to be answered over the funding for each project. 6. Cumulative Impact 6.1 Further information is still required from Equinor on whether a Cumulative Affect Assessment has been addressed in regard to other schemes programmed in the area including Orsted HOW3, Vattenfall, Norwich Western Link and the A47 improvements. This greatly impacts the number of landowners affected and as this takes more land out of agricultural production. 7. Jointing bays and Link Boxes 7.1 There is still great concern over the design and siting of link boxes. Exact locations of link boxes are still to be agreed with landowners and occupiers. Link boxes do stand proud above ground level and due to the number where they can be parallel or staggered do greatly interfere with agricultural operations and are a hazard to farm machinery. It is extremely important to have further design information on link boxes and the siting of them. The preference is that link boxes are located within field boundaries where possible and Equinor must accept the interference they cause. Due to so many underground cable schemes coming forward there is now a greater understanding of the size of link boxes and the interference caused generally. 8. Outline Code of Construction 8.1 The NFU has particular that it would like to see included in the outline code of construction/ environmental management plan which covers how practical on the ground matters are dealt with during and after construction. Wording covers the following: a. Agricultural Liaison Officer b. Records of Condition c. Biosecurity d. Irrigation e. Soil Statement, Soil treatment and Soil Aftercare. f. Agricultural Land Drainage g. Treatment of Soils h. Agricultural Water Supplies 8.2 The NFU would like to see the wording in the CoCP to be included in to the Voluntary Option agreement and as yet this has not been agreed. 9. Flood Issues/Discharge of water 9.1 No details have been provided to landowners and occupiers on how any increase in surface run off of water from the haul road or the construction compounds will be dealt with during construction. Landowners and occupiers will not want to see discharge of water on to the land surface. Drains to be discharge into will need to be agreed. 10. Dust/Irrigation 10.1 Clarification is needed on how practical issues like dust will be controlled during construction and how can the effect on irrigation be minimised? 11. Access routes to the Order Limits 11.1 At the present time Equinor still need to agree access routes it would like to use to gain access to the working strip. 12. OFTO 12.1. The NFU would like to receive details from Equinor what happens once the onshore assets are transferred to an OFTO how will landowners and occupiers be able to communicate with the OFTO in regard to any issues which may arise. 13. Request to Attend Hearings and make Representations 13.1 The NFU will if required lodge a full Written Representations in due course and requests to make oral representations at the compulsory acquisition hearing or any other hearings which may be held on behalf NFU members which are directly affected by the proposed projects. Louise Staples NFU Agriculture House Stoneleigh Park Stoneleigh Warwickshire CV8 2TZ DATED 14th November 2022.