Representation by Ardent on behalf of National Grid Electricity Transmission Plc (Ardent on behalf of National Grid Electricity Transmission Plc)
- Date submitted
- 6 November 2023
- Submitted by
- Members of the public/businesses
This relevant representation is submitted on behalf of National Grid Electricity Transmission Plc (“NGET”) in respect of the Project, and in particular NGET’s infrastructure and land which is within or in close proximity to the proposed Order Limits. NGET will require appropriate protection for retained apparatus including compliance with relevant standards for works proposed within close proximity of its apparatus. NGET’s rights of access to inspect, maintain, renew and repair such apparatus must also be maintained at all times and access to inspect and maintain such apparatus must not be restricted. Further, where the Applicant intends to acquire land or rights, or interfere with any of NGET’s interests in land or NGET’s apparatus, NGET will require appropriate protection and further discussion is required on the impact to its apparatus and rights. Further detail is set out below. NGET owns or operates the following infrastructure within or in close proximity to the proposed Order Limits for the Project: NGET owns a 400 kV substation and multiple high voltage electricity overhead transmission lines within or in close proximity to the proposed Order Limits. These assets form an essential part of the electricity transmission network in England and Wales. The details of the electricity assets are as follows: Substations • Bolney 400 kV Substation • Assets within the DNO’s Bolney 132 kV Substation • Associated cables and apparatus Overhead Lines • 4VM 400 kV OHL Bolney – Ninfield 1 Bolney – Ninfield 2 • 4VF 400 kV OHL Bolney – Lovedean 1 Bolney – Lovedean 2 • Associated cable fibre Protection of NGET Assets As a responsible statutory undertaker, NGET’s primary concern is to meet its statutory obligations and ensure that any development does not impact in any adverse way upon those statutory obligations. As such, NGET has a duty to protect its position in relation to infrastructure and land which is within or in close proximity to the draft Order Limits. As noted, NGET’s rights to retain its apparatus in situ and rights of access to inspect, maintain, renew,repair and refurbishment such apparatus located within or in close proximity to the Order Limits should be maintained at all times and access to inspect and maintain such apparatus must not be restricted. NGET will require protective provisions to be included within the draft Development Consent Order (the “Order”) for the Project to ensure that its interests are adequately protected and to ensure compliance with relevant safety standards. NGET is liaising with the Applicant in relation to such protective provisions, along with any supplementary agreements which may be required. NGET requests that the Applicant continues to engage with it to provide explanation and reassurances as to how the Applicant’s works pursuant to the Order (if made) will ensure protection for those NGET assets which will remain in situ, along with facilitating all future access and other rights as are necessary to allow NGET to properly discharge its statutory obligations. NGET will continue to liaise with the Applicant in this regard with a view to concluding matters as soon as possible during the DCO Examination and will keep the Examining Authority updated in relation to these discussions. Compulsory Acquisition Powers in respect of the Project NGET objects to the compulsory acquisition of its land or rights over its land in the absence of an agreed form of Protective Provisions. As noted, where the Applicant intends to acquire land or rights, or interfere with any of NGET’s interests in land, NGET will require further discussion with the Applicant and NGET will require its standard Protective Provisions to be included within the Order NGET reserves the right to make further representations as part of the Examination process in relation to specific interactions with its assets but in the meantime will continue to liaise with the Applicant with a view to reaching a satisfactory agreement. NGET has specific concerns around the environmental mitigation that has been allocated by the project in NGET owned land. As a statutory undertaker with a duty to operate economically and efficiently, NGET must retain full control over land within its ownership in order to effectively deliver new infrastructure projects or connections to the electricity transmission network as well as renewing or expanding the existing substation. NGET therefore objects to proposals to use its land to deliver Rampion 2’s environmental mitigation and the environmental mitigation associated with the proposed extension on behalf of NGET. NGET acknowledges that land to the east of the substation has been included as permanent acquisition and objects to the proposed compulsory acquisition of its land. NGET requires the flexibility to design connections to the electricity transmission network in the most economic and efficient way and therefore it should not be constrained.. The design of the substation to accommodate the project is not yet completed and therefore it cannot be confirmed that an extension is the design that will be bought forward or that this is where it will be located. The title of this land must remain in NGET ownership It is essential that nothing contained within the Order prevents NGET from continuing to deliver future plans or from accommodating other electricity connection customers. Connections The Project proposes a connection to Bolney 400 kV Substation. In relation to the connection NGET is working with the Applicant to enter into connection agreements and other commercial arrangements at the relevant time. Further updates will be provided in the Statement of Common Ground.