Representation by Horsham District Council (Horsham District Council)
- Date submitted
- 5 November 2023
- Submitted by
- Members of the public/businesses
PLEASE SEE ATTACHED: Horsham District Council’s FULL Relevant Representation and PADSS will be submitted by email under separate cover. Horsham District Council’s Relevant Representation EXECUTIVE SUMMARY 1.1 Horsham District Council (‘HDC’) supports renewable energy generation and carbon reduction objectives to meet climate change commitments. However, as a Host Authority, HDC has some concerns regarding mitigations and enhancements associated with environment impacts, particularly regarding nature conservation and biodiversity and green infrastructure assets and impacts to residents and businesses given potential disruption during the construction phase, particularly regarding air quality and noise. HDC will continue to engage with the Applicant to ensure that should the DCO be granted, that social, economic, and environmental benefits are delivered. 1.2 HDC is the planning authority for Horsham District, except for the area of the district within the South Downs National Park. West Sussex County Council is the highways authority and Lead Local Flood Authority and Minerals and Waste Authority that covers Horsham District. The initial principal areas of concerns set out below therefore relate primarily to the administrative area and remit of responsibility of Horsham District Council. 1.3 Draft Development Consent Order and Securing Mitigation. HDC has concerns across several topic areas to the lack of commitment and securing mechanisms of mitigation, monitoring and compensation. It is not always evidently demonstrated that mitigation/compensation is captured in a securing mechanism and the Commitments Register appears more aspirational rather than embedded environmental measures. 1.4 Socio-economics and Transport. The Outline Skills and Employment Strategy (OSES) has limited detail and HDC is not listed as a consultee to this document. HDC is excepting to be a recipient and consultee regarding benefits given the adverse effects the district will experience during construction. The OSES is very high level and supporting existing local business is not included as an objective. The Community Benefits Package is treated as being divorced from the OSMS but there is opportunity for these to be aligned to assist in mitigation. HDC shares and supports the overarching concerns raised on highways and traffic impacts in particular regard to lack of sufficient mitigation including with the Outline Construction Traffic Management Plan, and with regard to mitigations for the purposes of managing traffic through the AQMA and Cowfold to minimise disruption to traffic flow impacts along the A272, and as identified as Principal Issues of Disagreement by WSCC in their capacity as responsible Local Highway Authority. 1.5 Terrestrial Ecology and Nature Conservation. HDC has concerns on the lack of demonstration of water neutrality, lack of clarity on mitigation, compensation, and terrestrial biodiversity net gain, and feasibility of habitat creation at Oakendene substation site. HDC shares and supports the overarching concerns raised on terrestrial ecology and nature conservation impacts, and as identified as Principal Issues of Disagreement, by WSCC. 1.6 Landscape and Visual Assessment. Concern is expressed in the lack of clarity on the delivery of advanced planting with the Outline Landscape and Ecology Management Plan, particularly (but not limited to) advanced and existing hedgerow management arrangements and how some mitigation measures are to be monitored and action including the reinstatement of hedgerows. Additionally, issue is raised with the consistently applied to the execution of the Landscape and Visual Impact Assessment methodology regarding receptors. This might mean that a potentially significant effect will be overlooked if effects are diluted down due to their limited geographical extents. These include visual receptors at Washington recreation ground. Key visual receptors are being assessed as part of a group and not being given dure consideration to reflect the actual likely effects experienced by those receptors. Landscape features at Oakendene substation are not described and assessed within the core assessment of effects, but rather dealt as part of the character area. This overlooks the actual likely effects on the landscape features as receptors in their own right, and the need arising from the LVIA to refine and fix more precise parameters to the development of the Oakendene substation site is identified. These are key and heavily relied upon to the success of the Project’s embedded environmental measures and proposed mitigation measures on the LVIA conclusions. 1.7 Noise and Air Quality. HDC is concerned regarding the adequacy of the noise and air quality assessments which both potentially underestimate the impacts arising from construction and operation phase effects. HDC has concerns regard the modelling of the noise sources, adequacy of the assessment of background noise levels, omissions from the assessment and validity of the assessment method. There is inadequate consideration of the Air Quality and emissions mitigation guidance for Sussex (2021) and insufficient robust mitigations pertaining to the Cowfold Air Quality Management Area. 1.8 Water Environment. HDC shares and supports the overarching concerns raised on water environment impacts to the design for the operational drainage at the Oakendene Substation works and that the current Flood Risk Assessment and design proposals for the Oakendene Substation do not truly reflect the winter flooding that occurs at his location, and as identified as Principal Issues of Disagreement, by WSCC in their capacity as responsible Local Lead Flood Authority. Concluding remarks on Horsham District Council’s Executive Summary Relevant Representation. HDC has identified its substantive areas of concerns in the preceding paragraphs of this Relevant Representation. HDC has also identified wide-ranging concerns about the draft DCO. These will be shared with the Applicant in due course and will be set out in the Council’s Local Impact Report. HDC looks forward to liaising with the Applicant on the draft DCO and proposed Section 106. It should be noted that the Council may wish to be party to legal agreements to secure mitigation for any impacts in Horsham District. HDC trusts that this Relevant Representation is of assistance to the Examining Authority and the Applicant. For clarification or further information on any issue raised in this Representation, please do not hesitate to contact Matthew Porter, Senior Planning Officer, Planning, at matthew.porter@horsham.gov.uk in the first instance.