Representation by Mr Derek Aldous
- Date submitted
- 14 November 2022
- Submitted by
- Members of the public/businesses
As a local resident, daily life will be affected by both temporary and permanent effects of the Dudgeon and Sheringham Shoal extension projects. These effects include cumulative impacts when considered in conjunction with other offshore wind projects coming ashore in Norfolk, large scale battery storage projects, and several other Nationally Significant Infrastructure Projects including the proposed East Anglia Green pylon route. The assessment of cumulative impacts should start from a common baseline of the present situation in which none of these projects have been carried out. Ten years ago, in 2012, the Docking Shoal offshore wind farm was refused consent due to an assessment of cumulative impacts. Studies were published afterwards describing lessons learned. One of these lessons was that the order in which decisions are taken can lead to an unfortunate outcome (e.g. Broadbent and Nixon, 2019). Five years ago, in February 2017, The Crown Estate announced the Round 2 Extension Opportunity, and in October 2018 it confirmed its intention to grant rights to extend the Dudgeon and Sheringham Shoal offshore wind farm leases. It completed a favourable Habitats Regulations Assessment in August 2019 and the leases for those projects were confirmed in September 2020. The lessons learned from the Docking Shoal decision have been available since that time and should be applied to the assessment of cumulative impacts arising from the Dudgeon and Sheringham Shoal extension projects. Seven years ago, as part of a consortium, the applicant took part in the IOTP (East) feasibility study of August 2015 and can reasonably be assumed to be familiar with the general nature of its main findings, which were submitted to the Planning Inspectorate for the Norfolk Vanguard and Boreas DCO examinations (EN010079-003084 May 2019, and EN010087-001737 February 2020). Integrated grid connection options were raised with the applicant during the public consultation for the Dudgeon and Sheringham Shoal extensions. In its Phase One Consultation Summary Report of November 2020 (page 14), the applicant stated: ‘In the absence of a legislative proposal to support a coordinated approach, it is not possible for us to integrate that option with the Extension projects.’ This statement was challenged during the consultation. Since then, National Grid ESO has published a Holistic Network Design which does not appear to require a legislative proposal in order to proceed. It would appear that residents may have been misled during the consultation.