Representation by Christine Warren (Christine Warren)
- Date submitted
- 5 June 2023
- Submitted by
- Members of the public/businesses
National Infrastructure Planning Temple Quay House 2 The Square Bristol, BS1 6PN 5th June 2023 Dear Sir/Madam Application by West Burton Solar Project Limited for an Order Granting Development Consent for the West Burton Solar Project (EN010132) I refer to the above application and our client Mrs Christine Warren of []. Mrs Warren lives at the property known as [], whilst it has a postal address of [] it is in fact located east of [] along a private lane called [] (USRN: []). Mrs Warren has now spoken to two different representatives on different occasions posting notices relating to the current stage of the DCO application on Gainsborough Road. Both representatives identified themselves to be from Dalcour Maclaren and both have told Mrs Warren that the private lane known as Sandhill Lane is to be used for HGV access for a period of 9 months for the construction of the Grid Connection for the West Burton Solar Project. We understand that on both occasions the representatives looked at plans before reiterating to Mrs Warren that access was definitely going via []. This has obviously come as a surprise to Mrs Warren as during the consultation on the proposed West Burton Solar Project scheme; as although reference was made to underground electricity cables connecting West Burton 1 to 4 to the West Burton Substation and from there to the National Grid substation at West Burton Power Station. The scheme consultation had referred to a new West Burton 400kV Substation and energy storage facility being located to the northwest of West Burton Power Station. As such the consultation on the proposed scheme has not involved land to the south of the Power Station becoming the siting of the Grid Connection as now proposed. The property St Ives is a residential property whose western and northern site boundaries abut the EDF owned Power Station site. The eastern boundary of St Ives abuts the West Burton Meadow Local Wildlife Site owned by the Nottinghamshire Wildlife Trust. The southern boundary of St Ives abuts Sandhill Lane. We have represented Mrs Warren for many years in relation to planning matters, she has asked us to look into this matter. It is therefore concerning that the information that has been given to Mrs Warren by representatives of the applicants is directly contradictory to the material that has been submitted for the DCO application. The nature and format of the information submitted for the DCO application which encompasses 356 documents is impractical for the general public to circumnavigate and trying to locate information even for ourselves is not a straightforward task. It is noted that the submitted Design and Access Statement Part 1 (Document APP-314) on page 100 still includes the ‘Substation and Energy Storage Area’ plan (unreferenced) being to the north-west of the Power Station site. This adds to the confusion regarding the grid connection. Mrs Warren is disappointed that nobody from the project has ever sought to visit her, given that her property is located immediately adjacent to the Power Station complex. Mrs Warren has noted that photographs have been taken of her property, which she assumes may be connected with the DCO application. The property St Ives is not indicated to be a ‘Singular building’ on Figure 8.8.4 West Burton 3 to West Burton Power Station - Residential Receptors. As such it must be assumed that no assessment of the impact of the proposal on this property has been made at all in the Environmental Statement. It calls into question whether the applicants are actually aware of the presence of St Ives as a residential property that lies less than 20m from the DCO Limits boundary. It is understood from the DCO Limits Plan that in fact Sandhill Lane is not included within the DCO application and instead construction access will be taken from the access track that was constructed in parrel to the south of Sandhill Lane for the quarry that has not yet been commenced (referred to as Access 101 on submitted plans). However, HGV movements on that access track would adversely affect the living conditions of the occupiers of St Ives through noise, disturbance and dust. It is unclear from the submitted information as to how long this construction access route would be used. It appears that this access would be used for Works Package 4 (National Grid Connection), Works Package 5 (Grid Connection Cable Route) and Works Package 5A(vii) as shown on Application Doc No. WB2.3. It is slightly unclear what Works Package 5A(vii) actually involves. In Appendix 4.1 (Engineering Drawings) we can find no drawings which details any of the actual works involved at the West Burton Power Station end of the proposal. In Section 4 of the ES (Scheme Description) paragraph 4.5.39 indicates that the: “Works at the existing National Grid West Burton 400kV substation Site to facilitate connection to the Scheme will include extending an existing busbar and associated gas zones to allow for the connection of a new generator bay with a 400kV circuit breaker, current transformers, metering current transformer/voltage transformer (CT/VT) units and line disconnector for the 400kV connection to the West Burton 3 Solar Site. Provision of a stand-alone building to house duplicate feeder protection systems, commercial metering systems, National Grid owned protection and control equipment and User Remote Control and data acquisition apparatus.” Despite our best efforts to look we can find not drawings that details these works within Works Packages 4 and 5 within the Power Station site further. The Grid Connection Statement in section 3.8 describes the West Burton National Grid Substation Works as: “Works will be required within the existing 400kV GIS extension building attached to the southwest of the main indoor West Burton Air Insulated Switchgear (AIS) substation, to create a new generation bay enabling the Scheme to connect to the grid. The works required are anticipated to consist of the provision of: • Extending Main Busbar 4 and reserve busbar ¾ gas zones to allow for the connection of a new Island Green Power GIS substation bay comprising the below; • A 400kV 3phase 4000A circuit breaker for control and protection of the outgoing circuit serving the new scheme; • A 3phase set of current transformers for protection of the new outgoing 400kV feeder circuit and the overlap with the National Grid system; • A 3phase High Accuracy Metering Current and Voltage Transformer assembly for commercial metering of the connection; • A 3phase 400kV Line disconnector/earth switch for isolation and earthing of the outgoing 400KV feeder circuit; • A 3phase set of 400kV high voltage cable sealing ends and cables connecting the National Grid site with the Scheme’s site at West Burton 3; and • A 3phase Power Quality ready Capacitor Voltage transformer. Also required is protection, control and ancillary apparatus for the circuit to be housed within a stand-alone building sized approximately 6m x 3 m, comprising duplicate feeder protection systems, commercial metering systems, National Grid owned protection and control equipment and User Remote Control and data acquisition apparatus.” Unfortunately, the Grid Connection Statement does not include any drawings of these works in order to allow their impact on the property St Ives to be assessed. In Section 4 of the ES (Scheme Description) paragraph 4.5.40 indicates that the Works Package 5A involves: “A 400kV cable circuit (consisting of up to 3 No. cables) cables will export the power generated by the Scheme and power stored at the BESS from the substation at West Burton 3, to the National Grid substation at West Burton Power Station. The length of this cable is approximately 9.93 km.” No specific indication of what works are precisely involved in the area marked as Works Package 5A(vii). It is assumed that as part of the cable route phase, all works will be underground with no above ground structures, however, from the information available we cannot be certain of this. There is contradictory information about the length of time the construction access routes will be used. The timetable given for the grid connection is specified as being an overall 21 months. Paragraph 6.13.15 of the Planning Statement states: “In relation to the construction of the cable within the Cable Route Corridor, it is anticipated that this will be built out in phases and each of the 19 accesses for the Cable Corridor Route will be used for approximately 90 days during the construction phase. It is likely that four or five accesses will be in use concurrently. It is forecast that each access will generate up to eight arrivals and eight departures per day for the delivery of material and equipment. Around half of these will be HGV trips and half LGV trips. There will also be around 10 construction workers per access, arriving by car and shuttle bus.” However, the Planning Statement does not give any details of the construction access impacts associated with the Grid Connection in Works Package 4. We do of course note that the representatives from Dalcour Maclaren posting the notices spoken to by Mrs Warren have said access 101 will be used for a 9-month period. The Transport Statement details different vehicle movements for the: “Cable Route Corridor • HGV – 16 (32 total movements) • LGV – 16 (32 total movements) • Car/Shuttle associated with construction workers – 40 (80 total movements)” There is no information in the Transport Statement that seems to deal with the construction access impacts associated with the Grid Connection in Works Package 4. This is an important omission. There is also no explanation or consideration as to why the reasonable alternative of utilising the access Power Station access gate and ‘South Road’ within the Power station site cannot actually be used to access both Works Package 4 and Works Package 5A(vii) instead of access 101. To get from the temporary access route into the Power Station site will already necessitate removal of part of the hedgerow boundary to the Power Station site to get to Works Package 4. This would be no different to the situation if access was instead taken through the Power Station access gate and ‘South Road’ with part of the hedgerow boundary then removed to get to the area of Works Package 5A(vii). This alternative option would remove vehicle movements from being immediately adjacent to St Ives and the Local Wildlife Site and instead use the existing Power Station road network that was specifically created to facilitate two-way HGV vehicle movements. Should you require any further information, or if you want to discuss any matters, please do not hesitate to contact me. Yours sincerely Anthony Northcote HNCert LA(P), Dip TP, PgDip URP, MA, FGS, ICIOB, MInstLM, MCMI, MRTPI Executive Director